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Public Speaking

IRAS CRS Compliance Reviews: immediate steps and practical solutions




What the IRAS will look at in priority: what you can do about it immediately and in the next 6 months. Review of the 23 hallmarks: what is often done incorrectly? What internal control must be put in place?


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” training, escalation procedures, internal controls and communication protocols;

  • Insufficient “anti-avoidance” training, detection or deterrent processes and controls;

  • Insufficient application of “reasonable- ness” 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

How to prepare to and deal with an IRAS CRS compliance review – practical aspects

  • IRAS’ expectations

  • Internal controls, testing

  • Documentation

  • Periodic reviews – internal or external?

  • Outsourcing – what is required?

  • Desk audits

  • On-site audits

CRS controls at entity level

  • Control environment

  • Control activities

  • System controls

  • Change management

  • Information and communication

  • Monitoring and review

CRS controls at process level: account identification

New accounts

  • New individual account identification and treatment

  • New entity account identification and treatment

  • Review of account opening documents – what is required?

  • Opening of accounts

  • What to do in the case of a breach of account open- ing procedures?

Preexisting accounts

  • Determination of preexisting accounts

  • Optional treatments in Due Diligence procedures of pre-existing accounts

  • Review procedures for individual accounts

  • Review procedures for entity accounts

  • Identification and treatment of undocumented accounts

CRS controls at process level: 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

CRS controls at process level: Account closure procedures

  • Identification of closed accounts

  • Finalising closed accounts

  • Recording closure of accounts

CRS controls at reporting level

  • Managing errors and amendments for CRS Reports/Returns

  • Common operational risks at a reporting level

  • Aligning reporting software solutions with data solutions

  • CRS FATCA "logic"at a reporting information data mart level

  • Datamart vs transaction processing systems : which data is the "Golden Source of Truth"

  • The "baton passing" problem

  • The "reverse baton passing" conundrum

CRS desktop audit: how to be prepared

  • A response tailored for different businesses. A Bank’s response is not efficient for a Fund, etc

  • Certain risks are more real in certain businesses. What are they?

  • You know your business, the tax authorities may not

  • "They don’t understand my business" is a complaint. What’s an effective solution instead?

  • A strategic response to the desktop audit

  • After receiving an inquiry from the authorities, how to come out smelling good

  • Finalisation of an IRAS CRS compliance review

  • What are the next steps and expectations by the IRAS

  • Ensuring operationalized compliance



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