Tax Regulatory Services

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FATCA & CRS / AEOI Services 

Robust FATCA and CRS compliance, from classification and due diligence to reporting, controls and delegation

FATCA and CRS (AEOI) obligations require financial institutions to identify reportable account holders / investors and their accounts, collect and validate documentation, determine classifications, perform due diligence, maintain controls, file annual reports and retain a defensible audit trail (register of actions).

FATCA and CRS compliance was never a simple, annual reporting exercise. But tax authorities’ expectations continue to increase. Legal requirements necessitate governance, policies, documented controls, reliable data, consistent operational procedures and readiness to respond to tax authority reviews.

BDO Luxembourg’s Tax Regulatory Services team helps financial institutions manage FATCA and CRS obligations efficiently and securely. We provide advisory, compliance, reporting, outsourcing, delegation and/or sponsoring, training, and audit support services tailored to the client’s structure and operational model.

Our AEOI services

AEOI Advisory Services

We provide efficient, practical, and technically sound support for FATCA and CRS questions arising in day-to-day operations or during complex transactions.

Our services include:

  • FATCA and CRS technical hotline
  • Determination of FATCA and CRS status of entities
  • FATCA GIIN registration and deregistration
  • Review or completion of self-certifications and U.S. Forms W-8
  • Review of account opening documentation, subscription forms, prospectus wording and internal procedures
  • Training and tailored technical workshops
  • Support in dialogue with the Luxembourg tax authorities

AEOI Operational Support, Due Diligence and Reporting

FATCA and CRS compliance relies on much more than annual reporting. Financial institutions must be able to demonstrate that account holder and investor due diligence has been properly performed, classifications are accurate, documentation is complete, controls are effective and reporting is supported by a reliable audit trail.

BDO Luxembourg assists clients across the full operational lifecycle of their FATCA and CRS obligations. We support documentation reviews, classification assessments, due diligence controls, remediation work, reporting preparation and filing, as well as post-filing interactions with the Luxembourg tax authorities.

Depending on your needs, our support can be provided through targeted assistance, partial outsourcing or a broader delegation model.

Our services include:

  • FATCA and CRS due diligence and reporting assistance
  • FATCA Sponsoring Entity services, where applicable
  • Investor onboarding
  • FATCA and CRS documentation and due diligence reviews
  • Review of self-certifications, U.S. tax forms and supporting documentation
  • Assessment and monitoring of account holder and investor classifications
  • Identification of reportable accounts and account holders / investors
  • Access to technology-enabled reporting tools for data preparation and filing
  • Data quality checks, consistency controls and reconciliation support
  • Preparation, review and submission of FATCA and CRS reports
  • Nil reporting support, where applicable
  • Post-filing support and follow-up with the Luxembourg tax authorities 
  • Maintenance of FATCA & CRS registers of actions / records of steps

AEOI Compliance Program Support

We assist financial institutions with the design, implementation and review of their FATCA and CRS governance frameworks, helping them establish robust processes, controls and oversight mechanisms.

Our services include:

  • Implementation or review of AEOI Compliance Programs
  • Drafting or review of AEOI frameworks, policies, procedures and registers of actions required under Luxembourg AEOI legislation
  • Design or review of internal control frameworks
  • Independent gap assessments, health checks and internal control reviews with prioritised practical remediation recommendations
  • Remediation planning and implementation
  • Internal audit support or co-sourcing engagements
  • Responsible Officer (RO) and Point of Contact (POC) support, including ongoing assistance with their regulatory responsibilities

AEOI Outsourcing Services

In addition to the operational support, due diligence and reporting services described above, BDO Luxembourg can assist financial institutions through a dedicated outsourcing model, whereby defined FATCA and CRS tasks are performed by BDO on a recurring or project basis.

This model is particularly relevant for banks and other financial institutions seeking to secure execution, absorb operational peaks, address backlogs, perform large-scale remediation exercises, or access specialised FATCA and CRS resources without increasing internal headcount.

Depending on the client’s operating model, internal organisation and specific needs, BDO can take charge of clearly defined workstreams while the financial institution retains appropriate oversight and decision-making responsibilities. 

Our outsourcing services may include:

  • Recurring operational support for FATCA and CRS processes
  • Outsourced review of client, account holder or investor files
  • Management of documentation remediation campaigns
  • Support with periodic documentation refresh exercises
  • Operational support during annual reporting cycles
  • Temporary reinforcement of internal teams during peak periods
  • Deployment of qualified BDO staff remotely or on-site
  • Coordination with tax, compliance, operations and relationship management teams
  • Knowledge transfer, handover and transition support
  • Preparation of status reports, issue logs and remediation trackers
  • Escalation of complex or sensitive cases requiring client validation


Tax Authority Aupport

We assist clients in responding to tax authority requests, preparing technical explanations, supporting remediation projects and managing post-filing follow-up.


Why BDO

BDO combines FATCA and CRS technical expertise with operational delivery capacity. We do not only advise on the rules. We help implement, document, test and report them.
From a targeted FATCA/CRS question to a fully delegated AEOI operating model, BDO can provide the level of support your organisation needs.


Key Contact

Sylvie Maestri

Sylvie Maestri

Partner - Tax Regulatory Services
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