Are Financial Institutions Always Regulated?

Offshore Tax with HTJ.tax · Mar 22, 2026 · 3m

A common misconception is that an entity must be licensed or regulated to qualify as a Financial Institution (FI) under the Common Reporting Standard (CRS). The OECD guidance makes clear: regulation is relevant—but not decisive.In this episode, we unpack what the rules actually say and why this distinction matters in practice.📘 The CRS Definition Comes FirstUnder the CRS framework (Section VIII), a Financial Institution is defined by function, not by regulatory status.An entity is an FI if it falls into one of four categories:• Custodial Institution • Depository Institution • Investment…