FATCA/CRS Awareness

FATCA/CRS Awareness

The US Foreign Account Tax Compliance Act (FATCA) and its OECD equivalent, the Common Reporting Standard (CRS) impose significant challenges on Foreign Financial Institutions (FFI). The introduction of FATCA’s Intergovernmental Agreements may help address legal hurdles (e.g. data privacy concerns) but at the same time they add to the complexity of the landscape.

FFIs need to review their organisational oversight, processes and systems and train their staff to mitigate the risk of potentially severe penalties for non-compliance. In terms of workflow, it seems sensible to align the FATCA/CRS and AML/KYC processes. But how well aware are your Customer Due Diligence analysts of the FATCA/CRS requirements and how is the information that is gathered validated?

FATCA and CRS impose customer identification and validation rules on FFIs that go well beyond what is currently generally required for AML/KYC purposes. More information needs to be collected, reviewed and validated and the burden on compliance is increased by requiring all accounts to be reviewed for US indicia. Thresholds are lower than most banks currently require for AML/KYC purposes and customer profiles need to be continuously monitored for any changes. Moreover, contrary to AML/KYC, FATCA/CRS is not a risk-based effort.

Target Audience

Client facing staff, customer support staff, junior Compliance officers, and New Hires. This course is also very well suited for non-bank actors dealing with this topic, such as Fund Managers, Trust & Company Services Providers, FinTech and RegTech companies.

Knowledge Test & Certification

Each module will end with a Knowledge Check to test if the participants have understood the content of the training. The results of the tests can be saved or printed and can serve as an audit trail for evidence towards the regulator

Course Objectives

At the end of the training, participants will be able to:

• Explain the background of FATCA and CRS initiatives and how this impacts the FI;
• Apply the FATCA and relevant IGA(s) requirements with respect to identifying US indicia;;
• Understand the benefits and limitations of applying AML/KYC processes to ensure FATCA compliance;
• Explain FATCA obligations towards the FI’s clients

 Course Content

Course Introduction

• What is the purpose of the Foreign Account Tax Compliance Act and the Common Reporting Standard?

FATCA & CRS

• Structure of the law
• What is the impact of FATCA/CRS?

The role of Financial Institutions

• What information needs to be reported to the tax authorities;

Knowledge Check

• Minimum passing score
• Audit trail: proof of completion
• Certificate of Completion