AEOI reporting engine¶


ID	`MOD-060`
System	SD06
Repo	`bank-risk-platform`
Build status	Deployed
Deployed	Yes
Last commit	`54197c02fff0ca78a988e6140d31778e59f05b46`

Approval gate (FR-807)¶

This module does not submit automatically. The submission orchestrator checks REGULATORY.RETURN_APPROVALS before transmitting to IRD or ATO. If no approval record exists for the current (run_id, return_code), the orchestrator aborts and alerts the Finance team. The approval is written by MOD-170 (Regulatory Submissions Portal) — a Finance officer reviews the assembled return in the portal Streamlit and clicks Approve. No code path in this module can bypass the gate.

Purpose¶

Automate FATCA and CRS due diligence workflows, account classification, and the annual FATCA/CRS/AEOI report preparation and submission to IRD and ATO.

What it does¶

The module manages the FATCA and CRS customer due diligence lifecycle: triggering self-certification requests at account opening, tracking certification receipt and validity, and applying the default classification rules where certification is not received.

Account classifications (US person, CRS reportable, non-reportable) are maintained in the module's classification register and updated automatically when new certifications are received or when account holder information changes in a way that affects classification.

Annually, the module extracts reportable account data from the classification register and the governed data pipeline, generates the FATCA XML and CRS XML report files in the formats required by IRD and ATO, and submits them via the prescribed e-filing channels. Submission confirmation receipts are retained.

The module provides the CCO with an annual FATCA/CRS compliance dashboard covering: accounts reviewed, classifications by type, and report submission status.

Compliance reason¶

REP-011 requires annual FATCA and CRS reports to be submitted to IRD and ATO and the underlying due diligence to be documented and retained. Manual management of self-certification and report generation creates compliance risk at the scale of the platform's customer base.

Commercial reason¶

Automated FATCA/CRS management reduces the tax reporting compliance burden on the Finance and Operations functions and eliminates the risk of late filing penalties and information exchange failures.

Module dependencies¶

Depends on¶

Module	Title	Required?	Contract	Reason
MOD-010	CDD tier assignment engine	Required	—	FATCA/CRS classification depends on the CDD profile data — tax residency and entity classification are part of the customer profile.
MOD-042	CDC pipeline — Neon logical replication to S3 Iceberg	Required	—	Account balance and interest data for annual FATCA/CRS reporting is sourced from the CDC pipeline in Snowflake.
MOD-104	AWS shared infrastructure bootstrap	Required	—	MOD-104 provisions the S3 Iceberg bucket (Snowflake external tables), KMS key, and bank-risk-platform EventBridge bus ARN. Required before this module can be deployed.
MOD-102	Snowflake account configuration & governance	Required	—	Snowflake account and governance provisioned by MOD-102 must exist before this module can read or write Snowflake.
MOD-170	Regulatory Submissions Portal	Required	—	Regulatory Submissions Portal owns the approval workflow and writes to REGULATORY.RETURN_APPROVALS; the submission orchestrator in this module gates on that table — MOD-170 must be deployed before any FATCA or CRS report can progress from VALIDATED to SUBMITTED.

Required by¶

Module	Title	As	Contract
MOD-170	Regulatory Submissions Portal	Optional enhancement	—

Policies satisfied¶

Policy	Title	Mode	How
REP-011	Tax & information reporting (FATCA/CRS/AEOI)	`AUTO`	Automates FATCA and CRS due diligence workflows, account classification, and annual report preparation and submission to IRD and ATO.
PRI-004	FATCA & CRS Compliance Policy	`LOG`	Customer financial data disclosed to overseas tax authorities (IRD/ATO) under FATCA/CRS is logged — every cross-border data transmission is recorded with recipient, data scope, legal basis, and transmission timestamp.
REP-005	Data Quality & Assurance Policy	`GATE`	Submission is gated by Finance officer approval in REGULATORY.RETURN_APPROVALS (via MOD-170); the submission orchestrator aborts if no approval record exists for the current (run_id, return_code) before transmitting to IRD or ATO.

Capabilities satisfied¶

(No capabilities mapped)

Part of SD06 — Snowflake Analytics & Risk Platform Compiled 2026-05-22 from source/entities/modules/MOD-060.yaml