France: Due diligence obligations for financial institutions under CRS

Identifying account holders and controlling persons

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August 7, 2025

Administrative guidelines issued on July 23, 2025, clarify the due diligence obligations of reporting financial institutions in identifying account holders and controlling persons for common reporting standard (CRS) purposes.

The guidelines specify that reporting financial institutions cannot solely rely on the presence of a Global Intermediary Identification Number (GIIN) to validate the plausibility of self-certifications when account holders claim to be financial institutions. Additionally, when account holders or controlling persons claim to be tax residents in jurisdictions offering Citizenship by Investment (CBI) or Residency by Investment (RBI) regimes, which are considered potentially high-risk, reporting financial institutions must undertake additional verification measures to confirm their tax residency.

Read an August 2025 report prepared by the KPMG member firm in France

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