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CRS & FATCA Compliance

Automatic Exchange of Information — what financial institutions and account holders need to know.

Overview

Understanding CRS & FATCA

🌐 CRS

Common Reporting Standard (OECD)

Multilateral framework for automatic exchange of financial account information between 100+ participating jurisdictions. Bahrain has been a CRS participant since 2018.

Reporting deadline: 30 September annually

🇺🇸 FATCA

Foreign Account Tax Compliance Act (US)

US legislation requiring foreign financial institutions to report accounts held by US persons. Bahrain signed an IGA (Model 1) with the US in 2014.

Reporting deadline: 30 September annually
Obligations

Who Must Report?

🏦

Banks

All licensed banks, including retail, wholesale, and Islamic banks

🛡️

Insurance Companies

Life insurers and investment-linked products with cash value

📈

Investment Entities

Fund managers, custodians, brokers, and trust companies

Data

Information Exchanged

Category Details Reported
Account Holder Identity Name, address, TIN, date/place of birth, jurisdiction of residence
Account Information Account number, balance/value at year-end
Income Interest, dividends, gross proceeds, other income credited
Controlling Persons For entities: UBOs with 25%+ ownership or control
Financial Institution Name and GIIN (for FATCA) of reporting institution
Action Plan

Compliance Steps

1

Register with CBB

Register on the CBB AEOI portal and obtain GIIN (for FATCA).

2

Implement Due Diligence

Collect self-certifications from all account holders to determine tax residency.

3

Identify Reportable Accounts

Screen existing and new accounts for reportable persons and entities.

4

Generate & Submit Reports

Prepare XML reports in prescribed schema and submit via CBB portal by 30 September.

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