Monaco Releases Updated CRS Guidance Publication

May 12, 2017

Paul Ogawa

Author

Sovos

This blog was last updated on June 27, 2021

Monaco recently published an updated publication on the implementation of the automatic exchange of information. This publication relates to how financial institutions must report under the OECD’s Common Reporting Standard (CRS).

This most recent update includes a few updates to existing language surrounding trusts, specifically with regard to controlling persons.

The settlor, trustee, protector, or beneficiary must always be considered as controlling person(s) regardless of whether they have effective control of the trust;
If a settlor/trustee/protector/beneficiary of a trust is an entity, the persons controlling the entity in question must be identified and named as persons holding control of the trust.
If said entity acts on behalf of a third party, that third party must be identified; if no identification can be made, then the persons controlling the entity must be the controlling persons.

Paul Ogawa

Paul Ogawa is a Senior Regulatory Counsel at Sovos Compliance. As part of the Regulatory Analysis team, his main areas of focus are state and federal tax withholding, the Affordable Care Act (ACA), and Canadian tax information reporting. Prior to Sovos, Paul worked as a litigation attorney in Boston area law firms, representing clients in insurance subrogation claims, family law matters, and employment disputes. Paul is a member of the Massachusetts Bar, earned his B.A. from Brandeis University and his J.D. from the Suffolk University Law School.

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