Self-Certification (CRS/FATCA)

When a customer opens an account, the bank cannot work out their tax residence alone, so it asks them to say. The form records the countries of tax residence, the tax identification number for each, the date and place of birth, and, for FATCA, whether the person is a US citizen or resident. Entities also state their type, such as active or passive, and list their controlling persons. The bank then checks the form for reasonableness against the other documents it holds, for example a foreign address or phone number that contradicts the declaration. If it spots a contradiction, it must get a fresh form or an explanation. In many countries a false statement can lead to penalties for the customer. If circumstances change, the customer must send an updated form, usually within a set time. Reports to tax authorities rest on these declarations, so a weak form means weak data downstream.

A customer opening a policy with a life insurer that has a savings component declares Country A as her only tax home. The insurer notes a recent Country B address on her utility bill and asks her to explain. She confirms she moved, submits a new form, and the insurer reports the policy to Country B.