Update products and reporting fields
Review CBDC and specified electronic-money offerings and relevant indirect crypto-asset interests. Systems must capture controlling-person or equity-holder roles, self-certification validity, account type, joint-account status and holder count, and new versus pre-existing status. For pre 2027 reportable accounts, role-reporting relief in 2027–2028 depends on whether the data is already electronically searchable.
Strengthen onboarding and residence checks
The infographic calls for all tax residences rather than treaty-tiebreaker selection, clearer controlling-person look-through, citizenship/residence-investment risk checks and timely valid self-certifications. AML/KYC reliance requires procedures substantially similar to FATF standards. Translate the checklist into staff guidance, system mapping and control changes for the 2027 regime; it does not say every e-wallet or every crypto product has identical CRS treatment.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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