Global tax transparency frameworks such as the OECD Common Reporting Standard (CRS) and FATCA are often discussed in technical or regulatory terms. In practice, their impact is increasingly visible in everyday banking interactions. A recent real-world example from France illustrates how these requirements are commonly reflected in customer journeys.
This example was shared by a client and reflects practices currently applied by French financial institutions.
The Regulatory Context: CRS and FATCA
CRS requires financial institutions in participating jurisdictions to collect and validate information on their customers’ tax residency. Institutions must obtain self-certifications and update them where required, including when there is a change in circumstances or as part of reviews mandated by local implementation rules.
While CRS originated within the OECD, it applies across a wide range of participating jurisdictions globally.
FATCA drives U.S.-focused due diligence requirements, particularly with respect to:
- Identification of U.S. tax residency
- U.S. nationality
- Detection of U.S. indicia
- Collection of U.S. Tax Identification Numbers (TINs), where applicable
Although FATCA is a U.S. regime, its operational approach has influenced how many non-U.S. institutions design onboarding and customer review controls.
In France, financial institutions must comply with EU Directive 2014/107/EU (DAC2), the CRS Multilateral Competent Authority framework, the France–U.S. FATCA Intergovernmental Agreement, and relevant provisions of the Code Général des Impôts and Code Monétaire et Financier.
These obligations apply both at account opening and throughout the lifecycle of the customer relationship.
A Recent Customer Experience in France
When logging into an online banking platform, the client was presented with a mandatory prompt as part of the digital journey. Before proceeding, the bank requested confirmation of the following points:
- Whether the customer was a French tax resident
- Whether the customer was a U.S. tax resident
- Whether the customer was a U.S. national
- Whether the customer held any other tax residency outside France
Completion of this step was required before the customer could continue within the online environment. Where responses suggested another tax residency or potential U.S. status, the workflow directed the customer to provide additional information.
CRS Self-Certification in Action
Following the initial confirmation, the bank requested completion of a full tax residency self-certification. The form required:
- Personal identification details
- Confirmation of all jurisdictions of tax residence
- TINs for each relevant jurisdiction, where issued and required under applicable rules
- A detailed table for jurisdictions other than France or the United States
- Specific declarations applicable to U.S. persons
- A signed certification attesting to the accuracy of the information
Customers were reminded of their obligation to inform the bank if their tax situation changes.
This process reflects standard CRS self-certification requirements under EU, international, and French law.
Why This Matters
For Financial Institutions
- CRS requires active due diligence rather than passive data collection
- Self-certification information must be validated and refreshed when required
- TINs must be collected in accordance with applicable jurisdictional rules
- Institutions must be able to demonstrate compliance under CRS and FATCA frameworks
Failure to meet these obligations can result in reporting gaps and regulatory exposure.
For Individuals
- Tax residency information must be accurate and kept up to date
- Cross-border connections may trigger additional documentation requests
- Delays or incomplete responses may delay servicing or trigger follow-up actions under an institution’s compliance procedures
Conclusion
This recent example from France demonstrates that CRS and FATCA requirements are no longer abstract regulatory concepts. They are now an integral part of everyday banking processes.
As institutions prepare for upcoming reporting cycles and evolving tax transparency requirements, examples like this highlight the importance of early readiness and strong customer data controls.
Foodman supports institutions and clients in navigating CRS and FATCA requirements with clarity, precision, and confidence.
