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📌 Singapore Issues First CRS Fines. A Wake Up For Banks

Posted: 01 May 2025 | Category: AEOI / CRS Compliance

Singapore’s Inland Revenue Authority (IRAS) has issued its first formal penalties for non-compliance under the Common Reporting Standard (CRS), signalling a firmer regulatory stance on automatic exchange of information.

This marks a significant moment for one of Asia’s most prominent financial hubs, and a timely warning to institutions operating under CRS obligations globally.

🔍  What Happened?

In late April 2025, IRAS announced administrative penalties against several financial institutions for:

  • Incomplete or inaccurate account holder data,
  • Failure to conduct proper self-certification procedures,
  • Delays in CRS return submissions, and
  • Inadequate controls to detect and prevent reporting errors.

While IRAS did not name the institutions involved, it confirmed that penalties ranged from SGD $5,000 to $50,000, depending on the severity and recurrence of the breach.

🛠️  Why This Matters

Until now, Singapore’s AEOI regime has emphasised education and voluntary remediation. The shift to enforcement reflects:

  • Increased maturity in the CRS framework,
  • Pressure from global tax authorities (especially OECD partners), and
  • A growing expectation for robust, audit-ready compliance systems.

This aligns with a wider global trend: CRS is no longer about filing reports — it’s about embedding permanent controls.

🧩  What Firms Should Do Now

Whether based in Singapore or elsewhere, financial institutions should take this opportunity to:

  • Revisit entity classification and onboarding procedures, ensuring all self-certifications are complete and correctly recorded;
  • Perform a data accuracy review across previously reported accounts;
  • Validate governance and escalation protocols around non-compliant or undocumented accounts;
  • Engage a third-party advisor to conduct a health check before your next CRS deadline.

 

⚖️  Our View at Edwards Fosse

This enforcement action won’t remain isolated to Singapore. As global AEOI systems mature, tax authorities in the UK, EU, UAE, and Hong Kong are expected to follow suit.

Now is the time for firms to proactively strengthen their CRS controls — not wait for a notice from the regulator.

Need to test your CRS readiness or resolve reporting risks before your next submission?
Contact our AEOI team today for a practical health check.

📌 IRS Finalises Form 1099-DA – What DA Brokers Must Do Next

13 May 2025 | Category: U.S. Regulatory Updates / Digital Assets

The U.S. Internal Revenue Service (IRS) has formally finalised Form 1099-DA, a new information reporting form that will dramatically reshape how digital asset transactions are disclosed for tax purposes. The change affects brokers, exchanges, wallet providers, and certain fintech platforms from January 2026, with voluntary adoption encouraged for the 2025 calendar year.


🪙  What Is Form 1099-DA?

Form 1099-DA (Digital Assets) is the IRS’s answer to the rapid growth of cryptocurrency and tokenised asset markets. It standardises how brokers report customer gains, losses, and transfers involving digital assets.

This includes:

  • Sales or exchanges of crypto and stablecoins
  • Certain NFT transactions
  • Wrapped tokens and Layer-2 instruments
  • Token swaps (in some cases)

It mirrors Form 1099-B, used for equities and securities, but with specific fields for blockchain activity, wallet addresses, and asset classifications.


🚨  Who Needs to File?

Any U.S. or foreign platform that meets the IRS’s expanded definition of a broker — including:

  • Centralised crypto exchanges
  • Hosted wallet providers
  • Some DeFi front-ends (if qualifying as intermediaries)
  • KYC-enabled fintechs facilitating token transactions

Important: Foreign entities operating platforms with U.S. clients must file if they hold a QI agreement or interact with U.S. financial institutions.

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