Joint IOTA - Global Forum Training Event on Verifying Compliance with CRS-AEOI Obligations

The Global Forum oversees the implementation of the CRS-AEOI commitments through a peer review process using specific Terms of Reference (ToR). Since 2023, a deeper peer review has been conducted based on the amended 2022 ToR, which will result in a compliance rating being assigned in 2025. Most of the IOTA's members have adopted the CRS-AEOI and are undergoing peer reviews by the Global Forum. One crucial aspect of effectively implementing the CRS-AEOI standard is ensuring that Reporting Financial Institutions comply with their reporting, due diligence, and record-keeping responsibilities. This requires jurisdictions to carry out effective compliance and enforcement activities. Supervising the compliance of Financial Institutions with their CRS-AEOI obligations has been a challenging area for many committed jurisdictions. In response, IOTA, in collaboration with the Global Forum, has developed practical training to assist their mutual members in ensuring the effective compliance of Financial Institutions with their CRS-AEOI obligations.

A welcome video message from Zayda Manatta, Head of the Secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes, and opening remarks by Eugenijus Soldatkovas, Work Programme Manager of the IOTA Secretariat, kicked off the event emphasising the importance of a strategic partnership between the IOTA and the Global Forum as well as a common goal of supporting the development of in-depth and sustainable capacities of IOTA members for verifying that Financial Institutions comply with their reporting, due diligence, and record-keeping obligations in practice.

Throughout the 3-day training event, participants worked on different case studies led by Global Forum experts Miguel Morelos along with Colin B. Yan, under the supervision of Hakim Hamadi, Head of the Capacity Building and Outreach Unit.

On the first day, Global Forum experts presented the key elements of an effective Administrative Compliance Strategy, focusing on verifying compliance with reporting, due diligence, and record-keeping obligations, as well as expectations during the peer review process. This was followed by a session exploring the recently developed and launched Model Manual for CRS Compliance Audits with case studies for discussion. In the latter half of the day, speakers from the IOTA member Tax Administrations - Austria and Finland - shared their experiences on CRS and FATCA risk assessment processes and CRS audits in practice. Gerhard Wallner from Austria and Dinis Kyllönen from Finland also delivered a joint presentation sharing their insights on the peer review process conducted in their administrations.

In addition, Global Forum experts presented the next steps in the context of the second round of the AEOI peer review process, including suggested deadlines by which jurisdictions should have sufficiently implemented compliance activities in practice.

The second and third days of the training event featured three case studies on conducting CRS compliance audits in financial institutions. After each case study presentation, attendees were divided into small groups to analyse and discuss when and how to conduct desk reviews and onsite reviews, including reviewing underlying documentation, as well as when and how to conduct in-depth or holistic reviews. Group assignments were followed by plenary discussions allowing the groups to explain the approach taken and findings in the case studies analysed by them. During the plenary sessions, all participants actively asked questions, shared their thoughts on group presentations, and discussed any outstanding comments related to the case studies.

At the end of the event, the Global Forum experts proposed strategies for utilising the knowledge gained over the training to help participants conduct similar training and share the knowledge within their respective jurisdictions.

The event was led by Alexandros Roukalis, the IOTA International Taxation Expert with the support of Eugenijus Soldatkovas, the IOTA Work Programme Manager, and was moderated by the Global Forum’s experts: Colin B. Yan and Miguel Morelos, under the supervision of Hakim Hamidi.

All training event materials and photos are now available on the event’s webpage (for registered users of the IOTA web portal only).