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OECD Invites Public Consultation on Closing CRS Loopholes

OECD Invites Public Consultation on Closing CRS Loopholes

The Organization for Economic Co-operation and Development (OECD) has released a consultation document inviting the public to provide input on the misuse of CBI and RBI programs. The main aim of the document is to prevent investment migration schemes from circumventing Common Reporting Standards (CRS).

OECD’s Common Reporting Standards were developed and implemented per a G20 request on 15 July 2014. The CRS calls on OECD member countries to gather information from their financial institutions and exchange this information with other members on an annual basis. This information is often used for the due diligence processes commonly followed by investment migration programs.

While several member countries that offer citizenship by investment programs have signed onto the CRS (Cyprus, Malta, St Lucia, St Kitts & Nevis), many others have not, including Grenada, Dominica, and Antigua & Barbuda.

The recent public consultation document seeks to identify at-risk countries whose investment migration programs may be used by persona non grata to circumvent the CRS. The OECD press release further outlines its four main goals for the document:

  1. Assess how these schemes are used in an attempt to circumvent the CRS.
  2. Identify the types of schemes that present a high risk of abuse.
  3. Remind stakeholders of the importance of correctly applying relevant CRS due diligence procedures in order to help prevent such abuse.
  4. Explain the next steps that OECD will undertake to further address the issue, assisted by public input.

While the document seeks public input on how to prevent the misuse of CBI/RBI schemes, it is also an effort to enlist the public’s help in providing evidence of past abuses. Anyone interested in providing insight or other relevant information can do so by email at CRS.Consultation@oecd.org. The deadline for contributions is 19 March 2018.


OECD Press Release
OECD Common Reporting Standards
OECD Consultation Document

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