Who is a Controlling Person under CRS?

For Passive NFEs, Controlling Persons are the natural persons who exercise control over the entity. The OECD Commentary aligns the Controlling Person concept with the FATF beneficial ownership definition and typically uses the 25 percent threshold, though jurisdictions can require lower thresholds based on local AML standards.

Are crypto assets in scope?

Yes, increasingly. The OECD adopted the Crypto-Asset Reporting Framework (CARF) in 2022, with a recast CRS in 2023 to include certain electronic-money products and central bank digital currencies. CARF reporting starts in many jurisdictions from 2026 onwards, beginning a parallel exchange regime for crypto-asset service providers.

 Glossary
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 Compliance
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 Common Reporting Standard
 

Compliance

Common Reporting Standard

CRS

Common Reporting Standard is the OECD multilateral framework for the automatic exchange of financial account information between tax authorities.

What CRS is

The Common Reporting Standard (CRS) is the OECD-developed multilateral analogue to FATCA. Approved by the OECD Council in July 2014 and operationalised through the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information, CRS now covers more than 120 jurisdictions that exchange account-level data with each other annually.

Under CRS, every Reporting Financial Institution (banks, custodians, certain investment entities and certain insurance companies) must identify the tax residence of each account holder, look through passive entities to identify Controlling Persons (the CRS analogue of UBOs), and report the relevant accounts to the local tax authority.

The local authority then exchanges the data with each jurisdiction in which an account holder is tax resident.

CRS due diligence relies on a combination of pre-existing account records, self-certifications and indicia tests. New accounts always require a self-certification of tax residence at onboarding, and changes in circumstances trigger re-certification. Non-compliance by financial institutions is sanctioned at the national level.

When you will meet CRS

You will encounter CRS as a self-certification form at almost every non-US financial institution worldwide, asking for your tax residences and Tax Identification Numbers in each. Corporate accounts also require classification as Active or Passive Non-Financial Entity, and Passive NFEs must disclose their Controlling Persons, mirroring the UBO concept.

Where this comes up in our guides