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FATCA/CRS Gap Assessment

Identify gaps in your FATCA and CRS controls before they affect reporting accuracy or regulatory compliance.

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    About Our FATCA/CRS Gap Assessment

    FATCA and CRS compliance involves much more than submitting a report each year. The information in that report passes through several hands and systems first. Customer details are collected, tax residency is checked, accounts are classified and records are updated. A weakness at any stage can affect the final submission.

    That is where our FATCA/CRS Gap Assessment helps. We take a close look at the way your organisation handles these tasks. This includes checking policies, customer records, self-certification forms, tax information, account classifications and past reporting files.

    We also compare the written procedure with what employees actually do. The two are not always the same. At the end, you will know which controls are working, where the gaps are and which problems need attention first.

    FATCA CRS Gap Assessment

    What Our FATCA/CRS Gap Assessment Reviews

    We review how your team identifies reportable accounts, collects customer information, and checks the accuracy of FATCA and CRS reporting.

    1. Governance, Policies and Risk Assessment

    Who owns the FATCA and CRS process? Who checks the work? And who steps in when something does not look right? These may sound like basic questions, but unclear ownership is a common reason why issues remain unresolved. We examine your governance arrangements, policies, procedures and approval records. We also check whether responsibilities have been properly assigned to compliance, operations and senior management. Entity classification is reviewed as part of this work. Our team considers whether the organisation has correctly determined its FATCA and CRS status and can support that decision. Where relevant, we check registration records, Global Intermediary Identification Number details and related documents. Review dates, escalation routes, exceptions and record-retention practices are checked as well. If a policy looks complete on paper but is not being followed, the assessment will make that clear.

    2. Customer Controls, Screening and Monitoring

    A self-certification form may be signed and still be incomplete. A customer may move to another country, provide a new address or change the ownership of a company. Unless someone notices and follows up, the account information may no longer be reliable. We examine how tax residency details, Tax Identification Numbers and supporting documents are collected and checked. Depending on the scope, this can include both new accounts and accounts opened in earlier years. A sample of customer files is then tested. We look for missing information, inconsistent details, US indicia, changes in circumstances and unclear controlling-person records. We also check whether staff followed the required steps when information could not be confirmed. The result is not simply a list of faulty files. We trace repeated errors back to the process or control that allowed them to happen.

    3. Reporting, Records and Staff Training

    A reporting file is only as dependable as the information behind it. We select entries from previous submissions and trace them back to customer and account records. This helps show whether the figures and classifications can be supported. We look at how data is extracted, checked, approved and submitted. Reconciliations, nil returns, rejected files, corrections and missed deadlines are considered where relevant. If a third-party provider prepares the report, we check how your organisation reviews its work. Employees are also part of the assessment. We speak with the people responsible for onboarding, compliance and reporting to understand how they handle unusual cases. Training records and internal guidance are checked, but the real question is simpler: do employees know what to do when they find a problem?

    Our Approach

    The assessment is completed in four stages. The process stays focused on evidence, risk and realistic corrective action.

    1
    Understand Organisation’s Operation

    We start with your legal structure, business activities, products, customers and account types. This gives us the context needed to confirm the scope and identify the FATCA and CRS requirements relevant to the business.

    2
    Follow Process Throughout

    Policies alone do not tell the full story. We examine files, forms, systems and reporting records, then speak with the employees handling the work. This often brings manual steps, delays and undocumented workarounds to light.

    3
    Rank the Gaps

    Some findings need a quick fix. Others may affect hundreds of customer records or the accuracy of a regulatory report. We rate each issue according to its impact, urgency and likelihood of happening again.

    4
    Workable Action Plan

    The final report explains what we found, why it matters and what should happen next. Recommended actions can be assigned to named owners with reasonable completion dates.

    Who Is a FATCA/CRS Gap Assessment For?

    Banks and Depository Institutions
    Custodial Institutions
    Investment Entities and Funds
    Specified Insurance Companies

    Ideal for organisations preparing a report, responding to an audit, reviewing an outsourced process or dealing with known weaknesses.

    Why Choose Vertex Compliance?

    Clear Gap Findings

    A policy may say that a control exists, but that does not prove it works. We check the evidence behind your process and give management a clear account of where the organisation currently stands.

    Risk-Based Priorities

    Not every finding deserves the same response. We separate high-risk gaps from routine housekeeping points so your team can deal with the most pressing matters first.

    Practical Action Plan

    Recommendations are written for your organisation. We consider the systems you use, the people involved and the number and type of accounts you manage. The result is a plan that your team can realistically follow.

    Regulatory Review Readiness

    During an audit or regulatory review, your organisation may need to explain how a classification or reporting decision was reached. We help you organise the evidence, close weak points and document those decisions properly.

    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

    There is no fixed timeframe. A smaller review may take less time, while an organisation with several entities, systems or large customer volumes will require more work. We confirm the schedule after an initial discussion.
    No. We can examine the controls you currently use even if the policies are incomplete. Missing or outdated documents will be recorded as findings, along with practical steps for correcting them.
    Usually not. We normally agree on a sample of customer files, self-certifications, classifications and reporting records. The sample is selected according to the scope and the risks within your customer base.
    Yes. If you need further support, Vertex Compliance can help revise policies, correct customer files, improve working procedures and train employees. A follow-up check can confirm whether the agreed actions were completed.
    You receive a report setting out the work completed, the gaps found and the risk attached to each finding. It also explains what should be done next. Owners and target dates can be added to help track progress.
    No. A bank, an investment fund and an insurance company do not have identical operations or risks. We shape the assessment around your legal structure, activities, customers, systems and reporting responsibilities.