The document discusses the global compliance challenges arising from the automatic exchange of information regime, particularly the Common Reporting Standard (CRS) endorsed by the OECD and G20, which mandates financial institutions to report taxpayer financial data. This regime extends the principles of the US Foreign Account Tax Compliance Act (FATCA) and introduces extensive due diligence, reporting obligations, and customer classifications that highlight the need for financial institutions to adapt their compliance processes. With an ambitious implementation timeline beginning in 2016, financial institutions are urged to strategize for operational effectiveness and compliance cost management amidst increasing regulatory scrutiny.

1. Automatic Exchange of Information Regime
An emerging compliance challenge

2. 2
What started off as a US initiative
to clamp down on US citizens
evading tax—by imposing a 30%
withholding tax penalty under the
Foreign Account Tax Compliance Act
(FATCA)—has spread and triggered
similar initiatives on a global level.
While financial institutions globally
struggle to meet the full FATCA
compliance requirements, they must
also deal with a wider global tax
transparency initiative introduced
by the Organisation for Economic
Co-operation and Development
(OECD) in the form of Common
Reporting Standard (CRS).
In February 2014, G20 finance ministers and
governors endorsed the CRS as the new
global standard for the Automatic Exchange
of Information (AEoI). On May 6, 2014, a
group of 441
countries (the early adopter
group) committed to a specific and ambitious
timetable to implement the new standard
with an effective date of January 1, 2016.
On July 21, 2014, the OECD released the
full version of the Standard for Automatic
Exchange of Financial Account Information
in Tax Matters, including the detailed
Commentary on the CRS, which was
endorsed by G20 members in the recent
summit, held on September 20-21, 2014.
At the OECD Global Forum meeting held on
October 29, 2014, fifty one jurisdictions*,
many represented at Ministerial level,
translated their commitments into action by
signing the Multilateral Competent Authority
Agreement that will activate automatic
exchange of information. A further 38
jurisdictions also confirmed their commitment
to start the information exchange by
September, 2018, and it is expected the
number will increase in near future.2
Like FATCA, CRS requires financial institutions
around the globe to play a central role
in providing tax authorities with greater
access and insight into taxpayer financial
account data, which means Customer Due
Diligence (CDD) and reporting obligations
are set to increase considerably.
Note: *The specific implementation schedule
outlined by the early adopter group is only
applicable to the original 44 jurisdictions.

3. 3
CRS is not the first initiative aiming to
achieve greater transparency and tackle
offshore tax evasion. The European Union
Savings Directive (EUSD) for automatic
information exchange has been in place
since 2005, although it is currently limited
to reporting certain types of interest income,
and not all EU member countries participate
fully. In March 2014, the EU agreed to an
extension to the existing EUSD to include
new types of savings income, products that
generate interest or equivalent income,
life insurance contracts and a broader range
of investment funds. The member countries
have until January 1, 2016 to adopt the
national legislation necessary to implement
the extended directive, which will take effect
on January 1, 2017. The EU has also proposed
to expand the scope of its 2011 Directive
on Administrative Cooperation (DAC), which
foresees, among other things, the automatic
exchange of information for the following five
categories of income: employment, director’s
fees, life insurance products, pensions, and
immovable property.
In the UK, financial institutions also need
to comply with the International Tax
Compliance (Crown Dependencies and
Gibraltar) Regulation 2014, which is widely
known as ‘UK FATCA’.
It remains unclear if there will be an
alignment and consolidation among these
various directives and regulations. Therefore,
a strategic response to the wider AEoI
regime is imperative to avoid skyrocketing
compliance bills and to minimize the
operational impact of these initiatives.
Financial institutions need to develop
strategies that meet compliance requirements
in a cost-effective manner while supporting
broader business objectives.

4. 4
CRS HAS A MUCH WIDER SCOPE
THAN FATCA
FINANCIAL INSTITUTIONS
• CRS has a broad definition of “financial
institution” which includes custodial
institutions, depository institutions,
investment entities and specified insurance
companies.
• Some low risk financial institutions carved
out of FATCA (such as building societies,
firms with a local client base, certain
investment funds, firms with only low
value accounts and sponsored investment
vehicles) are also included under CRS.
PRODUCTS
• The products in scope include depository
accounts, custodial accounts, cash value
insurance contracts, annuity contracts and
certain equity or debt interests.
• Certain insurance products (such as
pension funds) excluded from pre-existing
remediation under FATCA may come into
scope for CRS. In addition, equity interests
in investment banking exchange traded
funds are treated as financial accounts
under CRS.
DUE DILIGENCE
• Due diligence requirements increase
considerably due to additional
jurisdictions, a reduction of the de minimis
carve-outs and a requirement to look
through passive entities to report on the
ultimate beneficial owners.
• Due diligence is based on tax residency
as opposed to citizenship, which may
require updates to Know Your Customer
(KYC) systems.
INFORMATION REPORTING
• The financial information to be reported
includes all types of investment income
(including interest, dividends and income
from certain insurance contracts) but also
account balances and sales proceeds from
financial assets.
• Under FATCA, institutions were required
to identify and report US citizens only. CRS
seeks to implement a multilateral reporting
regime (44 jurisdictions to start with) with
‘bulk’ reporting of financial account data.
Figure 1: Scope of CRS
CRS
Compliance
Scope
Financial
Institutions
Products
Information
Reporting
Due
Diligence
Source: Accenture, November 2014
CRS is modeled on FATCA
principles and follows the same
staggered approach in terms of
obligations. There are, however,
underlying differences which,
coupled with a wider scope and
ambitious implementation timelines,
present a significant compliance
challenge for many financial
institutions. To prevent taxpayers
from circumventing the CRS, it is
specifically designed with a broad
scope across four dimensions
as seen in Figure 1 below.

5. 5

6. CRS INTRODUCES EXTENSIVE DUE
DILIGENCE AND REPORTING OBLIGATIONS
CUSTOMER DUE DILIGENCE AND
CLASSIFICATION OBLIGATIONS
To identify and classify reportable
customers for all participating jurisdictions,
CRS introduces extensive due diligence
requirements. These procedures are different
for individual and entity customers and
also distinguish between pre-existing and
new accounts. To meet these requirements,
financial institutions must follow a
standardized approach with thorough due
diligence procedures while minimizing
downstream customer impact.
To limit the opportunities for taxpayers
to circumvent reporting by using interposed
legal entities or arrangements, the standard
also requires financial institutions to look
through shell companies, trusts or similar
arrangements, including taxable entities
to cover situations where a taxpayer seeks
to hide the principal but is willing to pay tax
on the income. Financial institutions will need
robust technical solutions to comply with
such extensive classification obligations.
PRE-EXISTING INDIVIDUAL
ACCOUNTS
As with FATCA, financial institutions are
required to classify their entire pre-existing
customer base for CRS; however, the de
minimis exemption has been removed.
Therefore, where previously institutions
were able to exclude a significant proportion
of their customer base by applying the
exemption, now they will need to carry out
appropriate due diligence procedures. This
implies that a larger proportion of customers
will need to be contacted to obtain self-
certification and/or documentary evidence.
For high-value accounts (that is, accounts
with an aggregate value of more than
$1 million), enhanced due diligence
procedures apply. These include both
paper-based reviews and a ‘reason to know’
relationship manager (RM) enquiry. Given
the number of jurisdictions involved, manual
enhanced review processes are expected to
be complex and have a downstream impact
on operational colleagues and RMs.
NEW INDIVIDUAL ACCOUNTS
CRS proposes self-certification for new
customers (customers on-boarded after the
CRS effective date), which require provision
of all tax residencies of the account holder.
This is different from FATCA, where the
confirmation of whether the account holder
is a US tax resident or not is sufficient.
Also, institutions are required to capture the
account holder’s date of birth, as well as the
Tax Identification Number (TIN) for all tax
residencies. Many institutions will have
to update their KYC systems and onboarding
forms to be able to capture the mandatory
data at the time of onboarding and record
it in a format which allows it to be used
for customer classification purposes by
the compliance rules engine.
The depository exemption for new bank
accounts has also been removed, which
will require additional customer contact
for self-certification purposes.
PRE-EXISTING ENTITY ACCOUNTS
Financial institutions are required to
determine whether the entity is a:
1. Reportable person, or
2. Passive non-financial entity (NFE)
Generally, the reportable status can be
determined based on anti-money laundering
(AML)/Know Your Business (KYB) or publicly
available information but where that is not
sufficient, self-certification is required.
Where the entity is a passive NFE,
the institution must determine the residency
of controlling persons. This information may
not be available in existing KYB data and
hence a self-certification will be required.
If allowed by domestic law, entity accounts
below $250,000 can be excluded from
review until the balance exceeds the
$250,000 threshold at the end of the
calendar year. This is different from FATCA,
where the balance threshold is $1 million.
Therefore, under CRS, a greater number
of entities will fall in scope of review.
NEW ENTITY ACCOUNTS
As is the case with pre-existing accounts,
financial institutions are required to
determine whether the account is held by one
or more reportable persons or by a passive
NFE with one or more controlling persons
that are reportable persons. There is no need
to determine any other status (such as FATCA
partner financial institution, a participating
foreign financial institution (FFI), a deemed-
compliant FFI, or an exempt beneficial owner).
As it is easier to obtain self-certification
from new customers at the time of
onboarding, the $250,000 threshold has
been removed, and institutions are required
to determine the tax residency of all
controlling persons of passive NFEs.
Institutions may also want to extend these
due diligence requirements to capture
multiple tax residencies for pre-existing
accounts. This may significantly reduce the
cost of fresh due diligence for each new
country which joins the CRS regime.
OBLIGATIONS FOR CHANGE
OF CIRCUMSTANCES
As with FATCA, financial institutions are
required to identify and react to any
change, addition or removal of information
to customer accounts or any associated
account. Therefore, institutions must
implement internal controls, systems and
processes to monitor, track and react to any
change in circumstances.
A change in circumstance is only relevant
if it affects the reportable status of the
underlying customer. For example, a change
in telephone number or address details within
the same jurisdiction will not result in any
change for reporting purposes. Therefore,
institutions will need to implement low-
impact detection methodologies to only react
to changes which affect reporting status.
If a change in circumstance causes the
financial institution to know, or have reason
to know, that the existing documentation is
unreliable, then it must contact the customer
to obtain a new self-certification to establish
the tax residency.
6

7. If a customer fails to respond to a self-
certification request, the institution
must treat the customer as reportable
for jurisdictions where it has indicia on
record (such as tax residency or current
residential address in a reportable
jurisdiction) or has reason to know, until
it is given the necessary information.
REPORTING OBLIGATIONS
CRS introduces a comprehensive reporting
regime covering all types of investment
income (including interest, dividends,
income from certain insurance contracts
and other similar types of income), and
also addresses situations where a taxpayer
seeks to hide capital that itself represents
income or assets on which tax has
been evaded (for example, by requiring
information on account balances).
Financial institutions must report the following
information for each reportable account:3
1. Name, address, TIN and date and place
of birth (in the case of an individual) of each
reportable person that is an account holder
of the account. In the case of an entity where
one or more controlling persons is identified
as reportable, the institution must report the
name, address, and TIN of the entity and the
name, address, TIN and date and place of
birth of each reportable person.
2. The account number (or functional equivalent
in the absence of an account number).
3. The name and identifying number (if any)
of the reporting financial institution.
4. The account balance or value (including, in
the case of a cash value insurance contract or
annuity contract, the cash value or surrender
value) as of the end of the relevant calendar
year or other appropriate reporting period;
or, if the account was closed during such year
or period, the closure of the account.
5. In the case of any custodial account:
a) The total gross amount of interest,
dividends and other income generated
with respect to the assets held in the
account, in each case paid or credited
to the account (or with respect to the
account) during the calendar year or
other appropriate reporting period; and
b) The total gross proceeds from the sale or
redemption of property paid or credited
to the account during the calendar year
or other appropriate reporting period
with respect to which the reporting
financial institution acted as a custodian,
broker, nominee, or otherwise as an
agent for the account holder.
6. In the case of any depository account,
the total gross amount of interest paid or
credited to the account during the calendar
year or other appropriate reporting period.
7. In the case of any account not described
in section 5 or 6, the total gross amount paid
or credited to the account holder with respect
to the account during the calendar year
or other appropriate reporting period with
respect to which the financial institution is
the obligor or debtor, including the aggregate
amount of any redemption payments made
to the account holder.
The reporting challenge may appear
far off with the obligation to file CRS
reports annually, starting September 2017
(covering the previous calendar year).
However, since many organizations are in
the process of defining their solution for
FATCA reporting, it is imperative that the
CRS requirements be taken into account
to minimize future compliance costs.
The early adopter group of 44 countries
has outlined an ambitious implementation
roadmap (as shown in Figure 2 below) for
these obligations. This is likely to present
a serious challenge for many organizations.
In our view, financial institutions will need
to act quickly to define their CRS compliance
operating model and should allow sufficient
time for implementation and delivery of the
underlying technical solution.
Figure 2: CRS Compliance Timetable
CRS Compliance
1. Effective Date
January 1, 2016
Required by obligation
*HV = High value customers
CRS Compliance Implementation timeline outlined by the early adopter group
Source: Accenture, November 2014
Note: Timelines are based on the joint statement by the early adopters group released in August, 2014. Access at: http://www.oecd.org/tax/transparency/AEOIjointstatement.pdf
January 1, 2016 January 1, 2016 December 31, 2016 (HV*)
– December 31, 2017
(Non-HV*)
September, 2017
onwards
2. Governance
and Compliance
3. New Customers
(Onboarding, identification
and classification)
5. Reporting4. Pre- existing
Customers (Identification
and classification)
7

8. WHAT DOES THIS MEAN FOR FINANCIAL
INSTITUTIONS NOW?
Figure 3: CRS Compliance RequirementsFinancial institutions will need
to assess if the processes and
solutions defined for US FATCA
are able to accommodate the
additional requirements of CRS
and to determine if, in the longer
term, there are more efficient ways
to organize, consolidate specific
capabilities to minimize operational
costs, and generate benefits for
the business. From a capability
perspective, the CRS compliance
requirements can be summarized
in the four areas shown in Figure 3.
KNOW YOUR CUSTOMER
Successful classification and reporting
comes down to the efficiency of onboarding
collection. From a data management
perspective, banks need to ensure that they
are accurate on the first attempt, and avoid
the problem of incorrect reporting. For the
attributes and data that firms now gather
at source—or need as output for classification
or reporting—there should be definitions,
data quality standards, guidance, and an
understanding by the staff of the importance
of high quality data. In that respect, KYC is
a critical piece and one which will heavily
influence the customer classification and
reporting design.
Financial institutions may have to update the
existing KYC and client onboarding systems
and procedures to be able to capture and
record additional data such as multiple tax
residencies and tax identification numbers.
Institutions should consider the impact on the
overall customer experience and try to keep
requests for information to a minimum, while
seeking to minimize the future changes and
operational impact of the design. For most
organizations, the key would be to assess
to what extent the customer onboarding
operating model designed for FATCA can
be leveraged for CRS.
Given the wide scope of jurisdictions and
removal of some of the de minimis exemptions,
a higher number of customers will be subject
to due diligence procedures, and additional
customer contact will be required to obtain
necessary self-certification.
Institutions need to define the appropriate
self-certification procedures and implement
systems to manage the workflow and
systematically record this information.
This information can then be accessed by
the compliance rules engine for customer
classification. The ability of firms to properly
process information from documentation
is essential. Firms can staff up to execute this
manually, but having tools and technologies
to automate this activity can be a huge
benefit, especially for larger organizations.
Organizations will also have to decide
whether they want to develop a central
shared services model for self-certification
management or manage it locally on
a business unit basis. Developing a centralized
capability can help establish standardized
processes, controls and colleague training,
and future changes to self-certification
forms should be easier to manage compared
to implementing the change across several
business units. However, the centralized
operation may require establishing a new
team. The greater the number of expected
self-certification requests, the greater the
volume of processing and subsequent full-
time equivalent requirements, which will be
a key decision factor in the overall design.
If a single processing center is created,
the servicing of multiple jurisdictions
(depending on data protection requirements)
may either need to be performed by a
dedicated team (with increased security
standards) or it may need to be sited
exclusively within the given jurisdiction.
Source: Accenture, November 2014
CRS
Compliance
Management
Information
and Reporting
Compliance
Rules Engine
Compliance
Data Store
Know Your
Client
8

9. COMPLIANCE DATA STORE
Data gathering, integration and the alignment
between the client data and the product
data is perhaps the biggest challenge for
financial institutions. Traditionally, data
gathering and integration has been very
focused on Standard Settlement Instructions
(SSI); as long as firms captured settlement
instructions, they were able to get the
payment out the door, and the transaction
was complete. Now, however, they need
to use both transactional and counterparty
information which has traditionally reposed,
respectively, in account and client databases.
Firms need to create a single client view and
therefore need to move from a product view
to a client view.
The second challenge is determining how firms
will evidence that they are compliant, with
a clear audit trail. The problem is no longer
merely capturing and processing the data; the
data must also be stored and retained for audit
and evidentiary requirements. This will require
more space as well as better integration with
current processes.
Firms may want to explore a meta-data
driven approach that keeps some of the
data where it lives, but creates a more unified
view holding only the key data elements
in a centralized location. This serves
as a “compliance data store”.
COMPLIANCE RULES ENGINE
CRS compliance requires the implementation
of a complex regulatory rule engine, which
can analyze the customer data and classify
the customer as either reportable or non-
reportable for each participating jurisdiction.
Any attempt at a standardized approach to
classify account holders will be complicated
due to differences among CRS, FATCA, Crown
Dependencies and Overseas Territories (CDOT)
agreements, the EUSD and—should the
proposed amendments be agreed—the DAC.
Moreover, under CRS, each time a new
country joins, institutions in participating
jurisdictions will have to undertake due
diligence procedure for back-book customers
to identify reportable accounts for the new
reporting jurisdiction. Therefore, scalability
and “future proofing” are crucial to reduce
the ongoing cost of compliance.
The higher volume of customers subject to
due diligence means that those firms which
adopted tactical or localized classification
procedures for FATCA will now have to invest
in robust technical solutions to reduce the
operational impact. They must also be able
both to remediate the pre-existing accounts
and to classify new accounts.
MANAGEMENT INFORMATION
AND REPORTING
Because there are multiple reporting regimes
running in parallel, financial institutions (FIs)
are now challenged by the “multiplicity” effect
of reporting, which will increase depending
on how many jurisdictions an FI has to deal
with, and the approaches to data classification,
customer engagement and reporting.
Differences between FATCA and CRS means
the FIs may not be able to use the same
reporting procedures for both standards.
FIs with a significant customer base outside
their home country, will be reporting big
volumes of data to local tax authority under
CRS and therefore manual or semi-manual
solutions will need to be reappraised.
The complexity of CRS reporting stems
primarily from the level of granularity
and extent of information to be reported,
coupled with the high quality of report
submissions that will be expected by local
tax authorities. Bulk transfer of customer
financial account information will also raise
data security and privacy concerns, calling
for robust tracking mechanisms.
CRS allows additional due diligence and
reporting requirements to be initiated
bilaterally between reportable countries,
which will also significantly increase the
complexity of the reporting solution.
Parallel to reporting, financial institutions
will need robust completeness checking and
reconciliation solutions to support internal and
external audit and evidentiary requirements.
The key assurance that institutions will need
to provide to auditors, tax authorities and
regulators is the proof that every single pre-
existing and new customer has been classified
for each participating jurisdiction and
appropriate due diligence procedures have
been carried out. Providing such assurance
will not be easy and will likely require
an effective technical solution.
9

10. ACCENTURE’S PERSPECTIVE ON CRS
CRS is not a mere extension
of FATCA and presents a significant
compliance challenge for many
organizations. A conscious effort
is required to develop a strategic
response to the wider AEoI regime,
both to avoid enormous compliance
bills and to minimize the impact
on customers and operations.
CRS is not ‘FATCA version 2.0’ and has
a much wider scope in many respects.
Financial institutions that took a tactical
approach to FATCA compliance—either by
creating manual processes or by terminating
business with US clients—need to reappraise
their approach to compliance with CRS.
As a result of the removal of some of the de
minimis exemptions and the greater number
of participating jurisdictions, CRS requires
institutions to remit a greater number of
accounts, contact additional customers,
and report a larger number of customers
with additional information. As a result,
institutions may not be able to use the same
solutions for FATCA and CRS. In the UK,
FIs will have to report under the CDOT and
potentially the revised EUSD as well, which
will further complicate the solution. At this
stage it is unclear how different reporting
regimes will co-exist or if there will be
a convergence of these standards.
CRS programs will be inherently complex
in nature given the range of obligations,
the relatively tight timescales and the
instability of requirements. The tools, analysis
and learnings from FATCA can provide the
starting baseline; however, the differences
are so profound that new processes, controls
and systems will inevitably be required. All
this is taking place in an intense regulatory
environment which will place great demands
on already constrained delivery resources.
Sourcing the required subject matter
expertise will be a key challenge.
A strategic technical response is critical
to meet compliance with AEoI emerging
regulations and to reduce the cost of future
compliance when new countries come on
board or introduce their own version of
FATCA. A sustainable and flexible
IT architecture should mean that institutions
are prepared for new countries joining, or for
evolving CRS requirements.
Some key considerations for a successful
CRS program include:
Future proofing and scalability. FATCA and CRS
are setting the scene for a wider global tax
transparency system, so institutions need
to ensure that their IT solutions are scalable
and the focus is on the ‘intent of the law’ as
opposed to the ‘letter of the law’ to achieve
sustainable compliance.
Managing overlapping and conflicting
regulatory obligations and timelines.
Financial institutions are dealing with
a number of regulations affecting the same
underlying capabilities. For example, the KYC
and onboarding capabilities are affected by
European Market Infrastructure Regulation
(EMIR), the Dodd-Frank Act, the Markets in
Financial Instruments Directive (MiFID) and
the Alternative Investment Fund Managers
Directive (AIFMD). While these regulations
are different in purpose, scope and technical
requirements, they all necessitate efficient
and up-to-date, client data processes.
Financial institutions should seek to
identify synergies between other regulatory
programs across key capabilities to
establish a single change portfolio to
overcome challenges related to resources,
budget and future proofing, and to
minimize the number of times the bonnet
must be raised to implement change.
Dealing with tight timetables. CRS delivery
schedules are demanding, especially when
balanced with other regulatory demands.
However, the obligations for KYC, due diligence
and reporting are staggered over the next few
years. Therefore, institutions should ensure
that any delivery strategy allows for individual
obligation timelines to be met rather than
packaging delivery into one drop with no
subsequent flexibility to phase in as required.
Consistency of interpretation and application.
Institutions with many business units,
operating across multiple jurisdictions should
ensure consistency of interpretation and
application of the regulation. These firms
should consider a centralized program team
driving interpretation, rule book creation and
a standardized operating model. These can
then be tailored to local needs if applicable.
Data remediation and quality control. Financial
institutions are likely to face their biggest
challenge in the data gathering and integration
space. They should, therefore, not undermine
the data remediation work that may be required
by starting late. Organizations should conduct
a strategic review to assess the benefits of
establishing or broadening the single customer
view across the organization and weigh it
against the effort required to develop localized
solutions to make an informed decision.
Establishing a robust control environment.
Institutions should agree, as early as possible,
upon the principles for management of the
ongoing compliance and maintenance of the
control environment across the organization,
including policies, standards and procedures.
Ownership, lines of control and responsibility
should also be determined. Where possible,
firms should try to leverage existing control
environment structures.
Considering custom versus packaged solution
options. Institutions should consider
the benefits of a vendor-packaged solution
for compliance rules engine and regulatory
reporting versus an internal custom build.
The key factor driving the decision will be
the solution’s ability to leverage and extend
the existing KYC/AML/FATCA platforms.
Considering the wider benefits of the CRS
program. The costs of compliance can
be high, depending on the make-up of the
organization. Considering the wider benefits
of CRS change can enhance the business
case. These include the benefits of further
centralization and remediation of customer
data and the opportunities that CRS change
can provide the AML/Sanctions team.
Establishing and maintaining operational
expertise. Across the organization, operational
expertise for CRS will be a challenge.
A successful implementation will require
subject matter experts in CRS legislation, tax,
legal and risk, as well as a strong, centralized
delivery team. Firms should consider
centralization of this knowledge and expertise
in a CRS Center of excellence.
10

11. HOW ACCENTURE CAN HELP
Accenture has extensive regulatory
change management and delivery
experience and has helped many
global financial institutions with
their FATCA programs. We can help
conduct the feasibility studies
to identify detailed functional and
technical requirements, and help
define the appropriate compliance
strategy to minimize the impact
and cost to the business.
Accenture has developed a comprehensive
review of the new CRS regulatory
requirements. This review covers changes
related to due diligence, classification and
reporting and also includes a comparison
with FATCA requirements across these
capabilities. To respond to the new regulatory
requirements, we have also developed
a target IT architecture framework design
as seen in Figure 4 below.
The sample IT design includes a new
compliance rules engine, which can help
clients address all functional and technical
business requirements and also helps:
• Support the customer onboarding process
by performing all new functionalities
required for customer identification
and classification (both for pre-existing
and new customers).
• Interact with legacy systems to collect
the data required for classification
and reporting.
• Determine the final CRS status for each
customer and manage the self-certification
workflow.
• Report the required customer information
to local tax authority and provide a robust
reconciliation solution.
Accenture has FATCA solution design and
delivery experience in over 14 jurisdictions,
which can be leveraged to analyze an
existing FATCA solution and build a strategic
response to CRS in a pragmatic and cost
effective manner. We understand the wider
regulatory landscape and can help deliver
a consolidated compliance transformation
program to help minimize the overall
compliance cost. Moreover, we have strong
industry alliances with third party vendors
and can help select and implement the right
vendor solution for your organization.
Figure 4: Accenture’s Perspective on an Architecture Compliant with the AEoI Regime
Source: Accenture, November 2014
Customer Due Diligence
Securities Cash Account Other Payments
Compliance Rules Engine
(Customer Identification and Classification)
Self-certification Engine
(Electronic document storage and processing)
Product Blueprint
Management Information
and Reporting
Workflow Management
AggregatedPositions
AEoI Regulatory Reporting Engine
Customer’s Master Data
Data Management
• Customer identification
• Pre-existing account
due diligence
• Periodic reviews
• Product classification
• Accounting and
balance information
• Customer data and
transaction reporting
• Reconciliation and
completeness checking
• Document management
system
• Compliance data store
Existing application
Onboarding PlatformAML/CDD
Enhancements/new logical modules
11

12. ABOUT THE AUTHORS
Jamie Woodhouse is managing director,
Accenture Finance & Risk Services. Based in
London, he leads Accenture UK and Ireland
Finance & Risk Services. Specialized in the
financial services space, Jamie brings his
broad experience and focus in regulatory and
compliance, operating models, cost reduction,
capital optimization, post-merger integration
and technology to guiding global financial
services clients in driving their operational
effectiveness and growth agendas. Jamie is also
a certified GARP (Global Association of Risk
Professionals) Financial Risk Manager (1999).
Peter Beardshaw is a managing director,
Accenture Finance & Risk Services. Based
in London, he leads the UK and Ireland
Finance and Risk Management consulting
practice. Peter brings nearly 20 years of deep
and broad experience in the risk and capital
management space, with a focus on large,
high profile Capital Markets and Banking
clients, assignments and transformations.
He and his team craft solutions to address
a wide range of prudential, conduct of
business, treasury, fraud and financial crime,
reporting and data, transformation agenda
and associated regulatory and regulatory
remediation situations and topics.
Sulabh Agarwal is a managing director,
Accenture Finance & Risk Services. Based
in London, he leads the finance, risk and
regulatory work for Banking clients in the UK.
With a focus on financial services, Sulabh
has extensive experience in transformation
engagements and defining and delivering
large-scale and complex regulatory programs
like Foreign Account Tax Compliance Act
(FATCA), anti-money laundering (AML) and
Directive on Payment Systems (PSD). He also
leads Accenture’s global FATCA and Common
Reporting Standard (CRS) community
of practice professionals.
Umer Hamid is a management consultant,
Accenture Finance & Risk Services. Based
in London, Umer’s primary focus is supporting
financial services clients in their compliance
transformation projects. He has extensive
experience in regulatory change management
assignments and is a subject matter expert
on regulations like Foreign Account Tax
Compliance Act (FATCA), the Organisation for
Economic Co-operation and Development’s
Common Reporting Standards (OECD’s CRS)
and the European Union Savings Directive
(EUSD) and leads Accenture’s efforts in these
areas within the UK and Ireland region.
ABOUT THE PUBLICATION
This paper looks at the impact of CRS
on financial institutions and suggests possible
strategies to help meet compliance in a cost
effective manner, while driving wider business
strategy both from a business and technology
perspective.
NOTES
1. “Automatic Exchange of Information,”
valid as of October 30, 2014, Organisation
for Economic Co-operation and Development
website. Access at: http://www.oecd.
org/ctp/exchange-of-tax-information/
automaticexchange.htm
2. “Major new steps to boost international
cooperation against tax evasion: Governments
commit to implement automatic exchange
of information beginning 2017,” Organisation
for Economic Co-operation and Development
press release, October 29, 2014. Access at:
http://www.oecd.org/newsroom/major-new-
steps-to-boost-international-cooperation-
against-tax-evasion-governments-commit-
to-implement-automatic-exchange-of-
information-beginning-2017.htm
3. “Standards for Automatic Exchange of
Financial Information in Tax Matters,” valid
as of October 30, 2014, Organisation for
Economic Co-operation and Development
website. Access at: http://www.oecd.org/
ctp/exchange-of-tax-information/standard-
for-automatic-exchange-of-financial-
information-in-tax-matters.htm
Copyright © 2014 Accenture
All rights reserved.
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High Performance Delivered
are trademarks of Accenture.
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