FATCA CRS Due Diligence: A Checklist for Compliance Officers

What is fatca crs reporting really about? It is not just about sending a file once a year. It is about the ongoing process of fatca crs due diligence.

To maintain fatca crs compliance, Financial Institutions must follow a strict due diligence procedure:

• New Accounts: Obtain self-certification forms on Day 1.
• Pre-existing Accounts: Review electronic records for "indicia" (signs) of foreign tax residency (e.g., foreign phone numbers).
• Change in Circumstances: If a client moves to a new country, you must update their fatca crs status within 90 days.

Failing these steps leads to "undocumented accounts," which attract higher withholding taxes and scrutiny from regulators.

For more details, please check out our FATCA/CRS Compliance Checklist