SERVICES
FATCA / CRS operations from classification data to reporting evidence.
Control entity and investor classifications, due-diligence data, reporting populations, validations, exceptions and filing-support outputs in one traceable workflow.
Overview
FATCA and CRS are tax-transparency regimes that require relevant financial institutions and investment entities to determine status, perform due diligence on account holders/investors and report specified information where applicable. Operationally, the work spans entity classification evidence, self-certification review, controlling-person data, reportable-account determination, data assembly, validation, filing-support files, corrections and evidence retention.
It cuts across fund formation, investor onboarding and annual entity/fund reporting. Because the lifecycle spans formation, investor onboarding and annual reporting, the underlying classifications, due-diligence records and reporting evidence need to remain connected rather than being rebuilt once a year.
Why it matters
The challenge is not simply generating XML. Entity status, investor tax residency, TINs, controlling persons, balances/values and reportable payments must be complete and consistent before a valid report can be produced.
Common operating challenges
- Entity FATCA/CRS status not centrally maintained.
- Self-certifications incomplete or inconsistent with KYC data.
- TIN/residency/controlling-person fields missing.
- Reportable population assembled manually each year.
- Schema/portal validation errors discovered late.
- Corrections and prior-year evidence difficult to reconstruct.
What we deliver
| Capability | What it covers |
|---|---|
| Entity classification support | Organise facts, prior classifications and adviser-approved status. |
| Investor due-diligence operations | Validate self-certifications and controlling-person data. |
| Reportable-population workflow | Apply approved jurisdiction/reporting logic. |
| Data preparation | Assemble identifiers, balances/values and required payments/income. |
| Validation | Run completeness, format, consistency and schema checks. |
| Filing-support output | Prepare controlled XML/data packs for authorised filer/provider where agreed. |
| Correction workflow | Track rejects, corrections and final evidence. |
Our role can be configured around a defined operating mandate: a recurring managed service, a technology-enabled client workflow, or a co-sourced model in which execution and review are split between Kelton, the client and appointed providers.
Inputs, workflow and outputs
Typical inputs
- Entity constitutional/classification information
- GIIN / tax identifiers where applicable
- Investor self-certifications
- KYC / beneficial-owner data
- Tax residency / TIN data
- Account balance/value and reportable payment data
- Prior filings / portal feedback
- Jurisdiction rules and adviser instructions
Controlled workflow
| Step | Activity | What happens |
|---|---|---|
| 1 | Determine scope | Identify entities and obligations based on authorised interpretation. |
| 2 | Validate classifications | Maintain entity/investor tax-status evidence. |
| 3 | Build reporting population | Identify reportable accounts/persons under approved rules. |
| 4 | Assemble data | Map identifiers, values and reportable amounts. |
| 5 | Validate | Run business-rule and XML/schema checks. |
| 6 | Review / hand off | Produce approval checklist and filing-support package. |
| 7 | Correct & archive | Process portal feedback/corrections and retain final evidence. |
Typical outputs
- Entity classification register
- Self-certification exception report
- Reportable-population file
- Validated FATCA/CRS reporting dataset
- XML or filing-support files where agreed
- Review checklist
- Submission/correction evidence archive
Controls and review
The workflow is designed so that automation does not obscure responsibility. Routine processing can be standardised; exceptions, material judgements and formal approvals remain visible and attributable.
- Authorised classification basis documented.
- Cross-check tax data against KYC/entity records.
- Mandatory-field, country-code and format validation.
- No silent override of missing TIN/residency/controlling-person data.
- Versioned rules by jurisdiction/reporting year.
- Formal filing/tax responsibility clearly assigned.
Responsibility boundary
We provide FATCA/CRS operating and technology support, including data preparation, validation and filing-support workflows. We do not provide tax or legal advice; formal classification interpretation, filing responsibility and regulatory accountability remain with the client and appointed advisers/providers.
Technology & expertise
Our operating model combines specialist knowledge with controlled technology. Domain experts define the rules, review logic and exception criteria; the technology layer makes the workflow repeatable, traceable and scalable.
Technology
- Rules engine by reporting jurisdiction/year.
- Self-certification extraction and validation.
- Entity/investor classification registry.
- Data mapping to reporting schema.
- XML generation/validation where in scope.
- Exception management and evidence retention.
Expertise
- FATCA/CRS reporting operations.
- Entity/investor classification workflow.
- Tax-data quality and self-certification review.
- Specialist review of exceptions and rule changes.
Expert knowledge is converted into controlled rules, SOPs, checklists, validation tests and exception criteria so that the operating standard is embedded in the workflow rather than dependent on one individual.
Delivery models
| Model | How it works |
|---|---|
| Managed Operations | We execute the agreed recurring workflow. Client and appointed-provider approvals remain explicit. |
| Technology Enablement | We implement the data, workflow and control layer for the client team to operate. |
| Hybrid / Co-sourced | Execution and review are shared through a documented responsibility and escalation model. |
| Transition & Implementation | We mobilise the workflow during a launch, provider change or target-operating-model transition. |
How the service changes by client or strategy
| Client / structure | Operating emphasis |
|---|---|
| Offshore funds | Annual reporting, registration/return requirements and portal workflows depend on local implementing rules. |
| Hong Kong / Singapore structures | Local law and reporting systems determine exact obligations and process. |
| Complex investors | Trust/entity/controlling-person structures increase due-diligence complexity. |
Frequently asked questions
Is FATCA/CRS just an annual XML filing?
No. XML is the end of a longer process involving classification, due diligence, reportable-population logic, data quality, review and evidence.
Can a service provider perform the work?
The OECD standard recognises that jurisdictions may allow service providers to perform due-diligence/reporting work, while the Reporting Financial Institution remains responsible under applicable law.
Can Kelton decide my tax classification?
We support facts, evidence and workflow; formal tax/legal interpretation remains with the client and appointed advisers.
What happens when a file is rejected?
Use a controlled correction lifecycle: identify error, fix source data/rule, regenerate, revalidate, resubmit through the authorised filer and retain evidence.
Discuss FATCA / CRS
Start with one workflow, one operating issue or one provider transition. We will map the current process, responsibility boundaries, required data and a practical first engagement.