FATCA / CRS
FATCA and CRS are global standards, for the Automatic Exchange of Financial Account Information (AEOI). FATCA was introduced first by the US Internal Revenue Service and is implemented via a series of intergovernmental agreements, with the CRS being developed by the Organisation for Economic Co-Operation and Development (OECD) and implemented via local legislation in participating jurisdictions. Both standards aim to minimise offshore tax evasion by creating enhanced due diligence and information reporting requirements.
The OECD have recently published CRS 2.0 which will go live at the discretion of individual jurisdictions over the next few years. This introduces significant changes, bringing new financial institution types into scope and increasing the information required to be reported.
Our services support financial institutions in meeting these obligations, including:
- Legal Entity Classification - We can help you by reviewing your entire group to determine the entity classification of each entity. When we do this, we also outline the follow up actions and compliance requirements as a result of the classification. We can also complete the relevant documentation (e.g. W-Series forms or self-certification forms on your behalf so that you can be confident that you are providing counterparties with valid and accurate documents.
- Account Holder Due Diligence - We can help by outlining the documentation requirements and giving clear guidance as to how best to optimize the validation and reasonableness process. We can work with you to integrate our solutions into your onboarding and data management processes, clearing the way for straight through processing and accurate reporting.
- Reporting - Our reporting tool can ingest the full account holder population and, based on the classification and tax residency details, determine the reportable population to produce the necessary XML files. We also check for data integrity and highlight any potential gaps or data quality issues. We can file the annual returns with the local tax authorities on your behalf.
- Compliance Program - We can help you implement the necessary compliance program and establish clear policies and procedures. We are also able to perform periodic reviews of compliance by reviewing the implementation of the procedures, alongside a sample review of account holder documentation and classification.