Three newly highlighted product categories
The infographic expands the highlighted scope to central bank digital currency, meaning digital fiat currency issued by a central bank; specified electronic money products; and indirect holdings of relevant crypto-assets and related accounts. The crypto category includes derivatives referencing relevant crypto-assets or interests in such assets. Institutions should review their products and assess both individual and entity account holders and financial accounts newly covered. The document is a CRS reporting overview, not a statement that every direct crypto transaction falls under this particular category.
What specified electronic money means
Specified electronic money products represent one fiat currency digitally, with examples such as e-wallet balances and prepaid cards. The infographic’s characteristics are issuance on receipt of funds, redemption at par value, and acceptance for payment by persons other than the issuer. Product classification should consider these characteristics together rather than relying on the label “wallet” or “card” alone. The source does not supply monetary thresholds or exclusions for individual products.
Report controlling-person and equity-holder roles
Reporting Singapore Financial Institutions must identify the specific role or roles of each controlling person linked to an entity account holder, including ownership, control through other means or senior managing official. Investment entities structured as legal arrangements, such as trusts, must also report equity-interest-holder roles. Multiple roles must be reflected where relevant; describing everyone generically as an owner omits the distinctions the infographic requires. Systems and processes should support the expanded information.
Self-certification and account details
Indicate whether a valid self-certification has been obtained for each account holder and, where relevant, each controlling person. Additional account information includes whether an account is joint and the number of joint holders; whether it is a depository, custodial, investment-entity equity or debt-interest, cash-value insurance or annuity account; and whether it is a new or pre-existing account. These are separate fields, not substitutes for the person’s identity or tax-residence information.
The limited 2027–2028 transitional relief
For reportable years 2027 and 2028, institutions need not report controlling-person and equity-interest-holder roles for reportable accounts maintained before 1 January 2027, unless that role data is already available in electronically searchable records. Both limitations matter: the account must be maintained before that date and the relief concerns role information only. Already searchable role data must still be reported. The infographic does not extend this relief to self-certification status, joint-account information or every newly required field, and does not offer the same relief for later reportable years.
Five strengthened due-diligence measures
All tax residencies must be declared: tie-breaker rules for dual-resident account holders no longer apply for this CRS purpose. Look-through requirements for controlling persons are clarified, including certain publicly traded entities. Consider citizenship-by-investment and residence-by-investment risks when assessing self-certifications. Apply strong measures to obtain timely valid self-certifications. Reliance on AML/KYC is permitted only where those procedures are substantially similar to FATF standards. Review onboarding and due-diligence procedures, update internal controls and provide revised staff guidance where needed. The infographic does not abolish treaty tie-breakers for every other tax purpose.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗