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The Training Course

This two day intermediate to advanced training course will provide delegates with a comprehensive understanding of the new United States Foreign Account Tax Compliance Act (FATCA) requirements, by combining theory with practice and by incorporating interactive learning elements. The course aims to demystify the complexity of both FACTA and the OECD Common Reporting Standard (CRS) frameworks. The course Expert Trainer will ensure that delegates fully understand the operational impact that FATCA and the OECD CRS will have on the business and on clients, as well as guiding delegates through necessary adaptation processes, compliance solutions, and the complexities of understanding the way the FATCA and OECD CRS frameworks operate around the world.



•Advanced knowledge and understanding of the FATCA and Model IGA frameworks; compliance requirements; the interaction of FATCA with trusts and passthru payments; and similarities and differences between FATCA and the OECD CRS due diligence and reporting obligations.

•Extensive Pre-Conference Questionnaire to identify delegate's key conference objectives.

•Comprehensive conference documentation (100+ page Training Manual, Definitions Brochure, Supporting Materials, colour FATCA PowerPoint presentations, Charts and Diagrams).

Post-course Expert Trainer follow-up to guarantee all key course objectives have been met.


Day 2

AEOI (FATCA & CRS) Operational Compliance


Session 5: AEOI Legal Analysis

·        A Legal Review of the Model 1(Reciprocal 1A); Model 1 (Non-Reciprocal 1B); Model 2 (No Pre-Existing Tax Information Exchange Agreement (TIEA) or Double Tax Convention (DTC) Required); Model 2 (Pre-Existing TIEA or DTC).

·        A Review of the CRS Commentaries.

·        A Legal Review of the IRS FFI Agreement (Form 8957).


Session 6: AEOI (FATCA & CRS) Operational Compliance

·        Comparing FATCA and CRS Frameworks and Identifying Key Differences.

·        Identifying and Assessing Compliance and Non-Compliance Costs, Organisational Gap Analysis and Developing Effective AEOI Compliance Frameworks.

·        Responsible Office preparation, Certifications, and Onboarding and Client Relationships.



Session 7: AEOI (FATCA & CRS) Risk Management

·        A Review of the Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures.

·        A Review of Jurisdictional Trends and Operational Risk Review.

·        A Review of AEOI (FATCA & CRS) Loopholes and Avoidance Strategies.




Session 8: AEOI (FATCA & CRS) Compliance Technologies

·        A Comparative Analysis of a range of AEOI (FATCA & CRS) software vendor solutions: including: (1) Vizor; (2) Thomson Reuters; (3) Newgen; (4) Bearing Point; (5) TAINA Technologies; (6) Capgemini; (7) IBM; and (8) US IRS.



Day 1

A Review of AEOI (FATCA & CRS) Regulatory Frameworks


Session 1: An Introduction to the AEOI Regulatory Framework

·        An Overview of the AEOI (FATCA & CRS) Regulatory Framework.

·        Key FATCA Aims, Objectives and Milestones and Global Implementation and Impact.

·        FATCA Definitions (FFI; P-FFI; RDC-FFI; CDC-FFI; NFFE; GIIN; FDAP Income; RO; IGA; USWAs; Gross Proceeds; Passthru Payments; Grandfathered Obligations; Active Income; Passive Income).


Session 2: The Three Pillars of FATCA

·        PILLAR I: Classification (Direct and Indirect US Accounts, Regulatory Exemptions), Due Diligence (Individual and Entity Accounts), Classification of Financial Entities.

·        PILLAR II: FFI and NFFE Documentation and Reporting Obligations, FATCA Reporting, Recalcitrant Accounts.

·        PILLAR III: 30% Withholding Penalty, Withholding Payments, FATCA Reporting Responsibilities, Civil and Criminal Penalties for Responsible Officers.


Session 3: The CRS Regulatory Framework

·        A Global Overview of CRS Reporting, Implementation Timelines, and 2017 and 2018 Reporting Deadlines.

·        A Review of the CRS (Standard for Automatic Exchange of Financial Account

·        Information), and the Model Competent Authority Agreement (Model CAA).

·        CRS Entity Management Liability and Sanctions for Errors and Non-Compliance.


Session 4: CRS Classification, Due Diligence, and Reporting

·        CRS Classification, Participating Financial Institutions, and Non-Resident Account Holders of CRS Participating Countries.

·        On-boarding of New Entity and Individual Accounts and Client On-boarding Solutions, Pre-Existing Account Due Diligence Procedures.

·        CRS Reporting (Foreign Debt, Equity Interests, Custody Accounts, Foreign Deposit Accounts), Reportable Accounts, and Enhanced File Review Procedures.




Rodrigo Zepeda is Co-Founder and Managing Director of Storm-7 Consulting. He is an expert consultant who specialises in derivatives and banking and financial services law, regulation, and compliance. He is an expert in a very broad range of regulatory compliance frameworks such as FATCA, the OECD CRS, MiFID II, MAD 2 MAR, PSD2, CRD IV, Solvency II, OTC Derivatives, CCP Clearing, PRIIPs, BRRD, AML4, and the GDPR. He holds a LLB degree, a LLM Masters degree in International and Comparative Business Law, and has passed the New York Bar Examination. He was an Associate (ACSI) of the Chartered Institute for Securities & Investment from 2004 to 2014 and is now a Chartered Member (MCSI). He has created and delivered numerous conferences and training courses around the world such as 'FATCA for Latin American Firms' (Santo Domingo, Dominican Republic, Panama City, Panama), 'MiFID II: Regulatory, Risk, and Compliance (London, United Kingdom (UK)), and 'Market Abuse: Operational Compliance' (London, UK). He has also delivered numerous in-house training Courses around the world to major international financial institutions such as The Abu Dhabi Investment Authority (MiFID II: Operational Compliance, Abu Dhabi, the United Arab Emirates), the United Nations Principles of Responsible Investment (MiFID II: Final Review, London, UK), and CAF, the Development Bank of Latin America (Swaps and Over-the-counter Derivatives, Lima, Peru). He is a Reviewer for the Journal of Financial Regulation and Compliance and has also published widely in leading industry journals such as the Capco Institute's Journal of Financial Transformation, the Journal of International Banking Law and Regulation, as well as e-books on derivatives law. Noted publications include "Optimizing Risk Allocation for CCPs under the European Market Infrastructure Regulation"; "The ISDA Master Agreement 2012: A Missed Opportunity"; "The ISDA Master Agreement: The Derivatives Risk Management Tool of the 21st Century?"; "To EU, or not to EU: that is the AIFMD question"; and "The Industrialization Blueprint: Re-Engineering the Future of Banking and Financial Services?".