Common Reporting Standards- self assessment and controls
1.????? Do you verify if the Account Holder has selected the correct CRS Classification (example: Reporting Financial Institution, Non-Reporting Financial Institution, Active NFE, Passive NFE, etc.)?
2.????? Please provide a detailed response on how do you ensure Account Holders are not misclassifying themselves as "Active NFE".
3.????? Please provide a detailed response on how do you ensure Account Holders are not misclassifying themselves as Financial Institution.
4.????? How do you monitor that Account Holders are not Account Shopping to avoid reporting on 31 Dec. (Account Shopping refers to moving account balances to other banks in jurisdictions that are not participating in CRS to low or Nil Balances on 31 Dec to avoid)?
5.????? How do you verify for accounts having Multiple Residency?
6.????? How do you ensure you monitor for change in circumstance and ensure CRS self-assessment completed by the entity is updated to the best of your knowledge (i.e., if an account holders updates its nationality or address, how do you ensure the CRS classification/status is re-assessed)?
7.????? Can an account holder open an account without obtaining CRS self-assessment?
8.????? How often does an account holder have to confirm its KYC details are up to date?
9.????? What actions do you undertake if up-to-date KYC details are not obtained from the Account Holder?
10.?? How often do you require account holders to re-confirm on their CRS Status / Self-Assessment?
Suggested Answers to CRS Thematic Assessment Questions
For Financial Institutions Holding Client Money and/or Providing Custody
1.????? CRS Classification Verification:
Answer: We use an automated system that cross-references the CRS classification selected by the Account Holder against the information and documentation provided during the onboarding process.
o?? Risk Assessment: Medium
o?? Control: Periodic audits and machine learning algorithms to detect anomalies.
2.????? Active NFE Misclassification:
Answer: We require additional documentation and conduct enhanced due diligence for entities classifying themselves as "Active NFE."
o?? Risk Assessment: High
o?? Control: Manual review by compliance officers.
3.????? Financial Institution Misclassification:
Answer: We have a two-step verification process involving both automated checks and manual oversight to ensure accurate classification.
o?? Risk Assessment: High
o?? Control: Regular training for compliance staff.
4.????? Account Shopping Monitoring:
?
Answer: We monitor account balances and transaction patterns, especially towards the end of the year, to detect account shopping.
o?? Risk Assessment: High
o?? Control: Alert system for suspicious activity.
5.????? Multiple Residency Verification:
Answer: We require additional documentation for accounts with multiple tax residencies and conduct periodic reviews.
o?? Risk Assessment: Medium
o?? Control: Automated flags for multiple tax IDs.
6.????? Change in Circumstance:
Answer: We have automated systems in place to prompt account holders to update their information in the event of a change in circumstances.
o?? Risk Assessment: Medium
o?? Control: Email reminders and account restrictions.
7.????? CRS Self-assessment Requirement:
Answer: No, an account cannot be opened without a completed CRS self-assessment.
o?? Risk Assessment: Low
o?? Control: Account activation restrictions.
8.????? KYC Update Frequency:
Answer: Account holders are required to confirm their KYC details annually.
o?? Risk Assessment: Low
o?? Control: Automated reminders.
9.????? Actions for Incomplete KYC:
Answer: Accounts with incomplete KYC details are temporarily restricted until the necessary information is provided.
o?? Risk Assessment: Medium
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o?? Control: Account status monitoring.
10.?? CRS Status Re-confirmation:
Answer: Account holders must re-confirm their CRS status every two years.
o?? Risk Assessment: Low
o?? Control: Automated reminders.
For Financial Institutions Without Reportable Accounts
1.????? CRS Classification Verification:
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
2.????? Active NFE Misclassification:
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
3.????? Financial Institution Misclassification:
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
4.????? Account Shopping Monitoring:
?
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
5.????? Multiple Residency Verification:
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
6.????? Change in Circumstance:
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
7.????? CRS Self-assessment Requirement:
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
8.????? KYC Update Frequency:
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
9.????? Actions for Incomplete KYC:
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
10.?? CRS Status Re-confirmation:
Answer: Not applicable as we do not hold client money.
a.????? Risk Assessment: Low
b.????? Control: N/A
?Please note that these are suggested answers Please check to fit the specific circumstances and compliance framework of your institution.