Countering tax evasion with CRS, all the way through the client chain

The rules touch the full client journey: onboarding new clients, opening accounts and every change to client data, down to a change of address. That is not a bounded project but an adjustment that surfaces everywhere in the chain. As long as procedures, systems and the people working with them were tackled separately, every solution shifted the problem to the next link, and reporting stayed dependent on what happened to be filled in correctly upstream.

First the frame. The governance structure and the project team were set up, with a project plan, the deployment of people and the necessary budgets. That fixed where choices were made and followed up.

On that basis followed the procedures and the supporting systems, including testing them, for onboarding new clients, opening accounts and processing changes to client data. Training and instructions for all involved employees belonged with delivery, not after it: without that last step, a procedure remains a document.

The moment when procedures, systems and behaviour were designed in coherence. The bank could report accurately because the processes around client intake and data changes were aligned to it, and because the employees knew why and how. An international regulatory change thus became not a standalone compliance exercise, but a movement that made the way of working more consistent across the whole client chain.

Compliance that works in daily practice, and an organisation better able to handle the next regulatory change. Clear procedures, supporting systems and prepared employees make sure regulation does not become a brake but an occasion to organise better.