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FATCA and CRS Policy and Procedure Development

Get tailored policies for accurate customer classification, due diligence, and FATCA and CRS reporting.

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    About FATCA and CRS Policy Development

    A FATCA and CRS policy should answer the questions employees face while doing their jobs. Which form should this customer complete? Is the information on the form reasonable? Does a change of address affect the customer’s tax status? Who follows up when a Tax Identification Number is missing?

    If the policy cannot answer these questions, employees will end up relying on assumptions or asking the compliance team to decide every case. Vertex Compliance prepares FATCA and CRS policies and procedures for financial institutions in the UAE. We write them around the organisation’s actual customers, products, systems and reporting arrangements.

    The purpose is straightforward: to give each team clear instructions. Employees should know what to check, what evidence to retain and when to escalate a problem. Management should also be able to see who owns each part of the process.

    About FATCA and CRS Policy Development

    What Our FATCA and CRS Policies Address

    The documents cover the decisions your employees need to make throughout the life of an account.

    1. Classification and Due Diligence

    Classification is not always obvious. An individual may have links to more than one country, while an entity may have several controlling persons with different tax residences. The procedures explain how to classify individual and entity account holders, review controlling persons and assess tax residence. They also address US indicia, Tax Identification Numbers and the information required on self-certification forms. Where customer information is incomplete or contradictory, employees are given clear follow-up and escalation steps instead of being left to make their own judgement.

    2. Account Reviews and Records

    Information collected during onboarding does not remain accurate forever. A customer may move to another country, provide a new telephone number or change the structure of a business. The policy explains which changes need another FATCA or CRS review. It also sets out who completes the review and how the decision should be recorded. Clear record-keeping matters here. If a decision is questioned later, the institution should be able to show what information it considered and why it reached that conclusion.

    3. Reporting and Internal Ownership

    Preparing a FATCA or CRS submission usually involves more than one department. Operations may hold the customer data, technology may generate the file and compliance may be responsible for the final review. Our procedures make those responsibilities clear. They explain how reportable accounts are identified, checked and approved before submission. They also deal with practical problems such as missing data, rejected records, reporting corrections and cases that need senior management involvement.

    Our Approach

    We do not begin with a standard policy and change the company name. We begin by learning how your institution handles customers and account information.

    1
    Understand the Current Setup

    First, we look at the organisation’s legal structure, products and account types. We also identify the teams involved in onboarding, customer reviews, data management and reporting. This shows us where the policy needs to provide direction.

    2
    Speak to the People Doing the Work

    Written procedures do not always reflect what happens in practice. We review the existing documents, but we also discuss the process with the employees who use them to streamline the process better.

    3
    Prepare the Documents

    The policy is then written around the agreed process. It explains each team’s responsibilities, the checks to complete and the records to keep. We also include escalation routes for situations that cannot be resolved through the normal process.

    4
    Help the Team Put It Into Use

    A policy only becomes useful when employees understand it. Once the document is approved, we can walk the relevant teams through the procedures and answer questions. If part of the process proves difficult to apply, it can be reviewed and adjusted.

    Who Is Our FATCA and CRS Policy and Procedure Development For?

    Banks and Credit Institutions
    Investment Entities
    Insurance Companies
    Other Financial Institutions

    This service may be useful if your institution is newly established, its existing policy is outdated or an internal review has found gaps in the current process.

    Why Choose Vertex Compliance?

    Policies That Match the Business

    We learn how your teams, systems and customer processes work before drafting anything. This produces a policy that reflects your organisation instead of a generic document that employees struggle to apply.

    Responsibilities People Can Understand

    Each procedure states who is expected to act. Employees can see who checks a self-certification, who follows up on missing details and who approves information before it is reported.

    Guidance for Real Situations

    The documents address the issues that arise during normal work, including incomplete forms, conflicting customer information, changes in tax residence and uncertain classifications. Employees have a route to follow when the answer is not immediately.

    Help After Delivery

    Questions may only appear once employees begin using the procedures. Vertex can support the rollout, explain difficult points and revise parts of the document that need to work better in practice.

    Meet the Experts

    Sarah Khan
    Vasantha Madan Mohan

    Managing Director

    Sarah Khan
    Sridhar Rajam

    Associate Partner

    Sarah Khan
    Arjun Mohan

    Director – Sales & Marketing

    Frequently Asked Questions

    A written policy gives employees one agreed process for handling FATCA and CRS. It explains how customers are classified, which information must be collected and who is responsible for reporting. It also reduces the risk of two teams treating the same situation differently.
    You can use one as a starting point, but it may not match your institution. A useful policy needs to reflect your products, account holders, systems and internal responsibilities. Otherwise, employees may still have to create their own process around it.
    The exact content will depend on your organisation. It may address entity and customer classification, self-certification, tax residence, US indicia, controlling persons and Tax Identification Numbers. It can also cover account reviews, changes in circumstances, record-keeping, annual reporting and escalation.
    Yes. We can review the policy you already have and compare it with the processes and forms currently in use. Where the existing content still works, there is no reason to replace it. We focus on unclear, outdated or missing parts.
    Yes. The policy can be explained to the teams responsible for onboarding, customer reviews, compliance, operations and reporting. Role-based training can also be provided if different teams need more focused guidance.
    Review it when the business changes its products, customers, systems or internal responsibilities. A change in the applicable requirements may also call for an update. Recurring errors and unresolved cases are another sign that the existing procedures need attention.