Which Countries Don't Take Part in CRS? The List and the USA

In our globalized, digitally connected world, governments are pushing harder and harder for financial transparency. That makes one question crucial for internationally active entrepreneurs, investors and private individuals who value their privacy: which countries don't take part in the automatic exchange of information?

Getting this answer right is the key to keeping your finances legally discreet and protecting your assets strategically.

While the net of global data exchange keeps tightening, some key jurisdictions still deliberately stay out of it. These countries offer legitimate ways to open offshore accounts beyond the reach of curious tax authorities at home.

This in-depth article gives you a detailed answer and a well-researched list of options.

We unpack the complex background of the Common Reporting Standard (CRS), developed by the OECD, and show you which countries deliberately take a different path.

At the center of it all is the USA, by far the most important of these countries, with a truly unique role.

We break down how AEOI (the automatic exchange of information) works in plain terms.

We also show you concrete, legal ways to restructure your finances strategically, by setting up a company abroad or opening a personal offshore account, and to make use of the advantages of a country staying outside CRS.

This knowledge is essential for making sound decisions about your financial future today.

1The basics: what is the automatic exchange of information (AEOI)?

To understand why certain countries stay out of global data exchange, you first need to understand the system they decided against.

The automatic exchange of information, known internationally as AEOI, is a global framework of rules.

This framework was driven largely by the OECD (Organisation for Economic Co-operation and Development).

The stated main goal of AEOI is to fight cross-border tax evasion and so-called capital flight worldwide.

1.1The Common Reporting Standard (CRS) as the global standard

The technical and procedural heart of AEOI is the Common Reporting Standard (CRS).

This standard is a precise set of rules that obliges financial institutions (banks above all, but also insurers and fund companies) in every participating country to follow a set procedure.

They must systematically collect information on the financial accounts of individuals and certain companies that are tax resident in another country, meaning they pay their taxes there.

The banks bundle this data and send it automatically once a year to the tax authorities of the account holder's home country. CRS is therefore the main tool that gives your tax office at home a direct view of your financial activity worldwide.

1.2The role of the OECD and how CRS came about

The OECD didn't develop these standards in a vacuum. Political pressure for more transparency grew sharply after the 2008 financial crisis.

The G20 countries tasked the OECD with creating an effective tool against tax evasion.

The result was the Common Reporting Standard, CRS, designed as the global gold standard for information exchange.

The OECD's work ensures that participating countries follow uniform rules.

The OECD also monitors how each country implements and complies with the CRS requirements. Every country that joins the system must write the OECD standards into its national law.

1.3What data is exchanged under CRS?

The scope of data reported under CRS is substantial, and it was deliberately designed to paint as complete a picture as possible of a person's financial situation abroad.

For every account holder concerned, the banks send the following account data to the tax authorities in the home country:

• The account holder's full name and address.

• Date of birth.

• Tax identification number (for example, your national tax ID at home).

• The number of every single account or securities account.

• The exact account balance or portfolio value at the end of the calendar year.

• The total investment income credited during the year. This includes interest, dividends, proceeds from selling securities and other income.

With this comprehensive set of financial and account information, it's very easy for your tax office at home to compare the income declared on your tax return with what's actually in your offshore accounts. Exchanging this data is the core function of CRS.

1.4The goal: global transparency to fight tax evasion

The intention behind the Common Reporting Standard and the whole AEOI framework is clear: to stop untaxed wealth being parked abroad.

Complete, automatic exchange of financial account information is meant to make tax evasion far harder worldwide.

By now, well over 100 countries and territories have committed to implementing these OECD standards.

But there is one very significant exception: a country with a major influence on the entire system.

2The key exception: the USA and its own path with FATCA

By far the most important and strategically interesting answer to the question of which countries stay out of the automatic exchange of information is this: the United States of America.

The US has not signed the Common Reporting Standard (CRS), and in all likelihood it never will.

Instead, the US runs its own system, developed earlier: FATCA (Foreign Account Tax Compliance Act). We explain in detail how CRS, FATCA and AEOI fit together on our page on OECD, CRS, FATCA and AEOI from a US perspective.

2.1FATCA vs. CRS: a decisive asymmetry

FATCA was enacted back in 2010. It requires foreign financial institutions and banks worldwide to report the accounts and financial assets of US persons (citizens and green card holders) to the American tax authority, the IRS (Internal Revenue Service).

So the flow of information is a clearly defined one-way street toward the US.

While the US receives extensive data on its citizens from the rest of the world, in return it sends CRS participating countries next to no information about bank accounts that foreigners hold at US banks.

This deliberate asymmetry in data exchange makes the US, de facto, one of the largest and safest havens for financial privacy. You could say the US is one of the most attractive non-CRS countries of all.

2.2Why doesn't the US take part in CRS?

The official US position is that its own FATCA system, through bilateral agreements (Intergovernmental Agreements, IGAs), pursues the same goals as CRS, so additional participation in the multilateral CRS is unnecessary.

In practice, though, this refusal means that traditional banking secrecy for foreigners in the US largely lives on.

While CRS has almost entirely hollowed out banking secrecy in Switzerland and other former tax havens, it is enjoying a renaissance in the US for non-US citizens.

This special role of the US offers considerable advantages to every non-US citizen who opens an account or forms a company in the US.

3The list of non-participants: which countries are still "offline"?

Besides the US, a number of other countries have so far not implemented the Common Reporting Standard, or only partially.

Treat this list of non-CRS countries with great caution, though: many of these countries do not offer the same stability and legal certainty as the US. When you ask which countries don't report to your tax authority at home, what counts is not only the lack of CRS participation but also the stability and legal certainty of the banking location. Every country on this list has its own quirks.

3.1An overview of other non-CRS countries

Countries that currently do not take part, or not fully, in the automatic exchange of information under CRS include:

• Paraguay: This South American country is known for its light regulation. However, its banking system is underdeveloped and political stability can be a risk. Opening an account can be complicated for foreigners.

• Philippines: A popular expat destination, but the country is known for corruption and bureaucratic hurdles. Local banks are often not set up for international clients.

• Montenegro: This Balkan country is often still described as a non-CRS location, but it began automatic exchange in 2023 and no longer belongs on this list.

• Georgia: With modern banks such as TBC Bank, Georgia is a sought-after banking location. Georgia officially joined CRS in 2024; in practice, banks ask for neither proof of address nor a tax ID, and no reliable, usable flow of data to European authorities can be observed so far.

• Cambodia, Dominican Republic, Guatemala, North Macedonia, Serbia: These countries are also non-participants, but for various reasons (weak banking systems, political risk, lack of legal certainty) they rarely offer a serious alternative for asset protection. Armenia formally no longer counts as a non-participant: it has officially joined CRS; in practice, banks ask for neither proof of address nor a tax ID, and no reliable, usable flow of data to European authorities can be observed so far.

3.2Why the US is the best choice among non-CRS countries

Compared head to head with any other country on the non-CRS list, the US offers unbeatable advantages for discerning clients:

• Political and economic stability: The US is the most stable and economically strongest country in the world.

• Reputation and acceptance: A US account at a renowned bank is respected worldwide and faces none of the restrictions that accounts in classic tax havens do.

• Legal certainty: The American legal system offers extremely strong protection of private property, including property owned by foreigners.

• Professional financial infrastructure: The US has by far the most developed financial centers and the widest choice of innovative banks and financial service providers. Many banks have branches dedicated to international clients.

• No stigma: Unlike offshore accounts on small Caribbean islands, an account in the US carries no negative stigma.

These factors make the US the only logical, professional choice for anyone looking for a foreign account outside the CRS system.

4In practice: opening a US account as a non-resident

Despite many rumors, opening a bank account in the US as a foreigner is entirely legal, and there are two main ways to do it.

Which route is right depends on your individual needs and goals.

4.1Option 1: a personal foreign account

Opening a personal account directly at an American bank is possible in principle. Our guide to opening a US bank account as a non-resident without an SSN shows how it works in detail.

However, many traditional US banks require non-residents to provide an American tax number (ITIN, Individual Taxpayer Identification Number) to open an account.

Applying for an ITIN is a bureaucratic process that requires a recognized need (for example, a US tax filing obligation) and can take some time.

For many of our clients, this route is therefore more cumbersome and slower than the second, far more flexible option.

4.2Option 2: a US LLC as the key to your foreign bank account

By far the most elegant, fastest and most efficient way to open bank accounts in the US is to form an American company.

The best-suited legal form for this is the Limited Liability Company (LLC).

Non-residents can form and run a US LLC entirely from abroad. To open a business account for the company at a US bank, the owner usually needs no personal ITIN.

Want a US LLC that stays tax-free in the US? Then our sister site zerotax.llc is the right place. It covers the LLC for owners who live outside the US and whose business does not take place in the US: no permanent establishment, no US tax on the profit. This site covers the opposite: companies that genuinely operate in the US, have a permanent establishment there and pay taxes in the US. Both are run by the same firm in Austin, Mount Bonnell Advisors.

5The role of the "Active Non-Financial Entity" (Active NFE)

In the context of CRS and the global fight against tax evasion, your company's classification is crucial if it ever opens an account in a CRS country.

One key distinction every bank has to make is between passive and active entities.

By OECD definition, an Active Non-Financial Entity (Active NFE) is a company that runs an active operating business.

Examples include trading, manufacturing, consulting and other service businesses. An Active NFE earns most of its income from active business operations.

For accounts held by passive entities, financial institutions in CRS countries must identify the Ultimate Beneficial Owners behind them and report their data under AEOI.

For a company classified as an Active NFE, this is usually not the case.

By forming an operating US LLC (for example for e-commerce, consulting, as a holding company for a start-up or for acquiring digital goods), you can obtain the coveted Active NFE status. This further increases your company's discretion, even when you deal with banks or business partners in CRS countries.

6Scenarios: who benefits from an account in a non-CRS country?

An account in a country without automatic exchange of information opens up many possibilities, relevant to very different people.

6.1Scenario 1: the digital nomad and online entrepreneur

If you earn your income online and independent of location, a US LLC with a business account is the perfect solution.

Revenue can be collected centrally in the US at a renowned bank, without account data flowing automatically to the tax office in your former home country. That makes bookkeeping for the start-up much simpler.

6.2Scenario 2: the investor and asset holder

To protect assets from third-party claims, political instability at home or the threat of expropriation, diversifying with an account in the stable, discreet US is a proven strategy. Offshore accounts in the US offer security here.

6.3Scenario 3: the international start-up

A start-up that operates internationally, and perhaps has its sights on the US market, benefits hugely from a US account.

Handling payments in US dollars becomes simpler, and access to US investors and customers gets easier. Forming a US company is often an important step in winning customers globally.

7Important considerations and the legal framework

Using foreign accounts in a country without AEOI is completely legal. It does, however, require strict compliance with your tax obligations in your country of residence.

7.1Your tax liability remains

A US account does not release you from the duty to declare the income earned there in your personal tax return (if it is taxable under the laws of your country of residence).

Banks not reporting is a huge advantage for your privacy, but it is no license for tax evasion. This is about legal strategies, not illegal practices. We offer no help with tax avoidance on this topic.

7.2The right structure is the key to success

Whether your plan succeeds depends largely on structuring your foreign company correctly and choosing the right banks and countries.

Professional advice is essential to avoid costly mistakes when opening the account and to get the full benefit of the structure. You need a clear agreement with the bank.

8What this means for you: the USA as the first answer to financial discretion

So the question we started with, "Which countries do not take part in the automatic exchange of information?", has a clear answer.

There is a list of several countries that do not follow the OECD's CRS standards, but the USA is by far the most strategically important, secure and professional option anywhere in the world.

By consistently staying out of the Common Reporting Standard (CRS) and running its own FATCA system built around its own interests, the USA offers non-residents a level of financial discretion that is unique in today's world.

Forming a US LLC is the most efficient and secure way to open an account with a US bank legally and without hassle, and to benefit from this system.

This takes you out of the automatic exchange of information under the CRS and protects your finances, your company and your privacy from blanket access by your home tax authority and other agencies.

If you want to learn more about your options for forming a US company and opening an account with a respected American bank, we are here with our expertise and support. You will find more recent articles in our News section.

Contact us for a thorough, strategic consultation.

In short

• Under the OECD's Common Reporting Standard, banks in well over 100 countries and territories report foreigners' accounts to their home tax authority once a year.
• The USA does not take part in the CRS. Through FATCA it receives data on US persons from around the world, but in return shares very little about foreigners' accounts at US banks.
• There are other non-participants besides the USA, but they rarely offer America's stability and legal certainty.
• You can hold an account in the USA personally or through your own US company.
• Your tax obligations in your country of residence remain: you declare your income there, even if the bank reports nothing.

How we help you

• US Tax ConsultationYour US tax question, answered by people who know both sides.
• US Bank Account OpeningYour own access to the American financial system, even without an SSN.
• Your US Tax ReturnForm 1040 or 1040-NR, handled in English.
• Withholding taxW-8 forms, withholding and treaty benefits, done right.