CRS and FATCA: what is actually exchanged, and why opacity is not a strategy

What is actually true

• They are not the same thing, and the difference comes down to asymmetry. FATCA is unilateral US law. Foreign financial institutions report accounts held by US persons to the IRS, backed by a 30% withholding threat on US-source payments, implemented through roughly 113 intergovernmental agreements. CRS works differently. It is multilateral and reciprocal. Participating jurisdictions collect account data on each other's tax residents and swap it automatically each year.
• 126 jurisdictions had signed the CRS Multilateral Competent Authority Agreement as at the OECD's 13 March 2025 status list. The United States is not among them, and this is the single most consequential fact in this section. The US receives data on its own taxpayers under FATCA, but it does not reciprocally report non-US persons' accounts under CRS. That is why calling the US the world's largest tax haven has become a defensible claim rather than a provocation. The reciprocity gap is real. But it is a gap in the plumbing, not a licence.
• Absence from the MCAA does not mean absence from CRS. Hong Kong is a CRS participating jurisdiction that exchanges data under bilateral competent authority agreements rather than through the multilateral instrument. Not on the MCAA list and does not exchange are two different statements. Conflating them has cost people money.
• Crypto stopped being outside the system on 1 January 2026. The OECD Crypto-Asset Reporting Framework and the amended CRS, known as CRS 2.0, both took effect 1 January 2026, with first reports due to national authorities in 2027. CRS 2.0 also pulls in specified electronic money products, central bank digital currencies, and indirect crypto exposure held through derivatives and investment vehicles.
• Here is where CARF commitments stand, according to the OECD Global Forum's list, last updated 23 June 2026. 46 jurisdictions will undertake first exchanges by 2027. That includes the UK, all EU Member States listed, Cayman Islands, Guernsey, Jersey, Isle of Man, Liechtenstein, Japan, Brazil and South Africa. Another 29 will follow by 2028, among them Switzerland, Singapore, Hong Kong, UAE, Bahamas, Bermuda, BVI, Panama, Canada, Australia, Cyprus, Mauritius, Seychelles and Thailand. Exactly one jurisdiction is committed only by 2029: the United States. Five jurisdictions the Global Forum identifies as CARF-relevant have made no commitment at all: Argentina, El Salvador, Georgia, India and Viet Nam.
• Here is the honest statement. Opacity was never a strategy, and it is not one now. Every structure that depended on an account staying unseen has been dismantled. CRS did it from 2017. Beneficial ownership registers did it. Economic substance rules did it. Now CARF is finishing the job. What survives is not concealment but substance. That means actually living where you say you live, actually paying what is due there, and having a real reason for the structure beyond simply staying invisible. The jurisdictions that still do not exchange are, without exception, places no UHNW family would trust with serious assets. That is not a coincidence. It is the trade the system was built to force.

Jurisdiction by jurisdiction

United States medium

The United States has not signed the CRS MCAA. It is the only major financial centre sitting outside the multilateral system. It receives data on US persons under FATCA through roughly 113 IGAs, but reciprocal reporting on non-US persons is limited and depends on the individual agreement. It has committed to CARF first exchanges only by 2029, later than every other committed jurisdiction. The asymmetry here is real. Treating it as a plan is not, because the US is not a jurisdiction where a non-US family can become tax-resident without also becoming a US taxpayer on worldwide income.

Hong Kong low

This is a CRS participating jurisdiction, but it exchanges information under bilateral competent authority agreements rather than the multilateral MCAA. That is why it does not appear on the MCAA signatory list. It has committed to CARF first exchanges by 2028. It is a useful example of why not on the list should never be read as does not exchange.

Georgia medium

This is a CRS MCAA signatory. But it is also one of only five jurisdictions the Global Forum identifies as CARF-relevant that have not committed to implement CARF, alongside Argentina, El Salvador, India and Viet Nam. That matters given Georgia's popularity with crypto-holding residents. It is a gap that is far more likely to close than to widen.

Switzerland, Singapore, UAE low

All three are CRS MCAA signatories. All three are exchanging data. All three have committed to CARF first exchanges by 2028. Their historical association with banking secrecy is 15 years out of date, and in a residency dispute it should be treated as a reputational liability, not an asset.

Cayman Islands, Guernsey, Jersey, Isle of Man low

These are CRS signatories and sit in the leading CARF group, with first exchanges by 2027, ahead of Switzerland, Singapore and the UAE. The offshore centres most associated with secrecy in the public imagination are now among the earliest and most complete implementers. That is precisely because their business model depends on staying off any blacklist.