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FATCA & CRS Frequently Asked Questions
Last updated: 29 sept. 2025
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FATCA (Foreign Account Tax Compliance Act): is a U.S. tax law requiring financial institutions outside of the U.S. to identify and report financial accounts held by U.S. taxpayers.
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CRS (Common Reporting Standard): is a global initiative by the OECD that mandates financial institutions to identify and report information on accounts held by non-resident individuals and entities to local tax authorities, which then exchange the data across jurisdictions.
Certain traditional financial services products or traditional financial services linked products: including futures on currencies, and tokenized equities, fall under the category of financial assets under FATCA and CRS:
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Firms like ours offering these products are categorized as Financial Institutions.
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We are, therefore, as any other institution would be, legally obligated to identify clients’ tax residencies and report certain account information for tax transparency purposes.
Yes. Financial derivatives such as futures on currencies and tokenized equities are considered financial instruments. When these are held in an account:
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The account is treated as a Financial Account under FATCA and CRS.
Any proceeds, income or balances associated with such instruments may be reportable, depending on the client’s tax FATCA and CRS status and tax residency.
We are required to collect and, where applicable, report:
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Your full name and address
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Country of tax residence
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Tax Identification Number (TIN)
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Date of birth (for individuals)
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Account numbers, balances, and certain gross proceeds details
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Entity FATCA and CRS classifications, and in certain cases information concerning controlling person(s) (for entities)
Failure to provide accurate and complete tax residency information may result in:
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Classification as a reportable or undocumented account.
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Restriction of services, including account limitations or withholding on certain payments.
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A Change in Circumstance refers to any event or new information that affects the validity of the tax residency information or self-certification you previously provided under FATCA or CRS.
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This may include changes in your personal details, tax status, or documentation, which could alter how your account is classified for reporting purposes.
Here are common examples:
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You move to a new country and change your tax residency
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You obtain a new tax identification number (TIN) or nationality
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Your entity’s status changes (e.g., it is no longer an Active NFFE)
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You update your mailing address to a different jurisdiction
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You submit new documents (e.g., passport, proof of address) showing conflicting residency information
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You become a U.S. person (e.g., by obtaining a U.S. passport or green card)
Under FATCA and CRS rules, we are required to maintain accurate and up-to-date tax residency information. If there is a Change in Circumstance:
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You must notify us within 30 days
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We may ask you to resubmit a self-certification form
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We may be legally required to report your account to tax authorities based on the updated information
Please use this form to let us know of any changes.
Yes. We take data security seriously and share FATCA/CRS data only with:
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Authorized tax authorities as required by law
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Using secure transmission protocols
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In line with GDPR and data protection regulations
For further guidance:
- We would also encourage you to speak to your tax advisor for assistance.
- Visit the IRS FATCA website
- Explore the OECD CRS portal