PAST EVENTS:
HONG KONG, TUESDAY 22 OCTOBER 2019, 9.00-16.00
> What will the Inland Revenue Department look at in priority? > What can you do about it immediately and in the next 6 months? > What is often not done or done incorrectly? > Which procedures, tools and internal control do you need to put in place?
AGENDA
HOW TO PREPARE FOR THE CRS AUDIT
Overview CRS Audit and Reporting Lifecycle
CRS Audit in Context - Global Forum CRS Peer Review Process
CRS Audit Overview: Entity, Process and Reporting
Reportable Account Lifecycle - Audit Risk Implications, at each of the following stages:
(a) Identification; (b) Classification;
(c) Monitoring; (d) Reporting; (e) Closure
Audit Failure: Top 5 areas of potential failure and how to avoid:
Insufficient CRS specific internal controls (CRS Manual vs. AML Manual);
Insufficient separation of CRS client base into CRS relevant categories;
Insufficient “change of circumstance” train- ing, escalation procedures, internal controls and communication protocols;
Insufficient “anti-avoidance” training, detection or deterrent processes and controls;
Insufficient application of “reasonableness” test to self certificate claims
Immediate steps:
internal audit, which areas to concentrate on?
reporting outcome assurance testing - sample reports vs. entire CRS client base?
staff competency testing, what to test, how to interpret results?
CRS/AML Manual review - key drafting provisions
General best practice steps:
Anti-avoidance training, explaining the requirements of the Mandatory Disclosure Rules for CRS Avoidance Arrangements;
Steps to reform CRS data management to ensure integrity of data;
Managing third party providers of CRS compliance services
CRS CONTROLS AT PROCESS LEVEL
Account identification – new accounts
New account identification and treatment
Review of account opening documents
Opening of accounts
Account identification – preexisting accounts
Determination of pre-existing accounts
Optional treatments in the Due Diligence Procedures of pre-existing accounts
Review Procedures
Identification and treatment of undocumented accounts
Account monitoring procedures
Monitoring of account details
Documentation and follow-up of CIC and other changes
Review of undocumented accounts, dormant accounts and excluded accounts
Account monitoring procedures / Trusts
Settlor: exclusion of benefit, surrender of power to revoke the trust
Beneficiary: removal or exclusion of a discretionary beneficiary, removal or exclusion of a fixed interest beneficiary
Trustee: retirement, removal
Protector: retirement, removal
Account closure procedures
Identification of closed accounts
Finalising closed accounts
Recording closure of accounts
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