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Financial institutions from more than 50 early adopter jurisdictions began AEOI/CRS Reporting in the first quarter of 2017, and in a few short months (January 2018) 51 "Wave 2 countries" including Switzerland, Singapore, Panama, Monaco, Japan, Hong Kong, Canada, Bahamas, Austria, Andorra will submit their 2017 reports.
Given that incorrect and/or late reporting may lead to penalties, firms are on edge as they tackle multiple challenges concurrently, including data management, deployment and operating models. These ramifications are compounded further by the sheer complexity of the CRS regulation.
With the last deadline for CRS (and some banks already reported for early adoption jurisdictions), the numerous operational challenges involved in CRS implementation needed to be addressed by compliance and operations specialists alike. If FATCA projects can provide the building blocks of CRS implementation, the scale and scope of the rules became clearer and financial institutions have realized that the increased complexity of CRS compared with FATCA meant there is a lot of work for them to do.
Consequently, the industry is focused not just on making sure it is collecting the necessary information for reporting, but also on ensuring that the appropriate governance procedures are in place to allow it to be accessed easily, and that clients are aware of – and on board with – the requirements.
Head of Regulatory Tax Regnology