The Common Reporting Standard has made automatic financial-data exchange the norm across more than 120 jurisdictions, but several countries remain outside the system. Their status varies: some opted out by design, some have not been asked to commit, and others are likely candidates for future adoption.
CRS was created by the OECD in 2014 to combat offshore tax evasion and reduce banking secrecy. Participating jurisdictions require banks to identify account holders who are tax resident elsewhere and automatically send that data to the relevant foreign tax authority once a year.
The information exchanged includes:
- Account holder name
- Address
- Tax identification number
- Account balance
- Interest
- Dividends
- Sale proceeds
The exchange is automatic. No government request or court approval is required, and the account holder is not notified when the information is sent.
The CRS network continues to grow. Thailand, Kenya, Uganda, Moldova, Ukraine, and Armenia have started exchanging within the last two years. The remaining non-reporting jurisdictions are a shrinking group, and non-reporting status does not remove tax obligations in a person’s home country.
United States
The United States never joined CRS. Instead, it operates FATCA, the Foreign Account Tax Compliance Act, which requires foreign banks to report American account holders to the Internal Revenue Service.
The system is asymmetric: the US collects data on Americans abroad but does not reciprocate in the same way CRS jurisdictions do. A non-American banking in the US generally falls outside automatic exchange.
The main investment migration route is the EB-5 Immigrant Investor Program. It grants a green card for a qualifying investment in a US commercial enterprise that creates at least 10 jobs.
The standard minimum investment is $1 million, reduced to $800,000 for projects in a Targeted Employment Area. EB-5 is residence by investment, not direct citizenship, but a green card can lead to naturalization after five years.
Egypt
Egypt appears on the OECD list of developing countries not asked to commit to CRS, with no date set for a first exchange. For now, account information held in Egyptian institutions does not automatically flow to other tax authorities.
The status is administrative rather than ideological, so it could change if the OECD changes its approach toward the region.
Egypt offers a direct citizenship by investment program, established in 2019. It has four routes:
- $250,000 non-refundable contribution to the treasury
- $300,000 real estate purchase held for five years
- $350,000 business investment plus a $100,000 donation
- $500,000 refundable bank deposit returned after three years
A $10,000 state fee applies to every route. There is no residence requirement.
El Salvador
El Salvador is on the OECD list of jurisdictions not asked to commit and has no FATCA agreement with the United States.
The article describes this as one of the clearer non-reporting positions in the Western Hemisphere. It also notes that El Salvador exempted all foreign-source income from taxation in 2024.
The main investment migration route is the Freedom Visa. It grants residence with an accelerated citizenship path in exchange for a $1 million investment in Bitcoin or US dollars.
The cost limits the program to a narrow applicant group, but it is described as one of the few routes offering quick citizenship eligibility for those who can afford it.
Serbia
Serbia appears on the OECD not-asked-to-commit list.
Because Serbia is an EU candidate, its non-reporting status is not necessarily permanent. Candidate countries typically align with European tax-transparency norms as accession progresses.
Serbia’s investor visa has accessible entry mechanics. The real estate route has no fixed minimum investment: an applicant can buy residential or commercial property anywhere in Serbia at any price point and obtain temporary residence within 30 to 60 days.
A company-formation route also exists, requiring around €50,000 held in a Serbian bank account.
Residence can lead to permanent residence after three years and citizenship after a further three years. Serbia also has an E-2 treaty with the United States, giving Serbian citizens a separate route to US residence.
Philippines
The Philippines is listed by the OECD as a developing country not asked to commit, with no date set for exchange.
The article notes that the Philippines is a substantial economy with a functioning banking sector, rather than a micro-jurisdiction built around offshore positioning.
The Special Investor’s Resident Visa grants indefinite renewable residence in exchange for a $75,000 investment in securities listed on the Philippine Stock Exchange or in a qualifying local enterprise.
A separate Foreign Investor Visa allows a broader range of qualifying investments. Neither route requires physical presence, and the SIRV remains valid as long as the investment is maintained.
Cambodia
Cambodia is on the OECD not-asked-to-commit list, with no exchange date.
The article notes that Cambodia has appeared on advisory shortlists of non-reporting banking jurisdictions, though account opening and documentation standards have tightened as global compliance pressure has spread.
Cambodia has a citizenship by investment program based on the 1996 Law on Nationality, which waived standard residence and Khmer-language requirements for qualifying investors and donors.
A December 2025 reform raised the thresholds sharply:
- $1 million investment in an approved-sector project
- $3 million cash donation to the national budget
Citizenship is typically granted within about six months, with no prior residence requirement. Cambodia permits dual nationality.
Paraguay
Paraguay is the main outlier. It is not on the OECD not-asked-to-commit list, but its account information does not currently flow automatically to other governments.
The OECD treats Paraguay as a jurisdiction of relevance for future CRS adoption, making its non-reporting status the least secure among the seven countries discussed.
Paraguay launched the Investor Pass in April 2026. It grants direct permanent residency without a temporary-residency stage through one of three routes:
- $150,000 in a qualifying tourism project
- $200,000 in Paraguayan real estate
- $200,000 in securities on the Asunción stock exchange
The older SUACE route still exists, requiring roughly $70,000 in business investment and local job creation.
The article highlights Paraguay’s low investment threshold, territorial tax system that does not tax foreign income, and three-year path to citizenship.
What non-reporting status does and does not mean
CRS reporting is based on tax residence, not simply where a person banks or holds a residence permit.
Acquiring residence in Serbia or the Philippines while remaining tax resident in a CRS country may change little about what foreign banks report.
The jurisdictions that matter most for lawful planning are those that combine non-reporting status with a territorial or zero-tax regime. The article identifies Paraguay and El Salvador as attracting particular attention for this reason.
The article also contains an unclear point: it says four of the seven countries offer a passport rather than just residence and names Egypt, North Macedonia, Cambodia, and El Salvador. North Macedonia is not one of the seven country sections discussed, so this comparison is unclear.
Non-reporting status should not be treated as a way around disclosure obligations. The legitimate uses described are asset diversification, geopolitical hedging, and lawful tax planning tied to a genuine change of residence.
Source article: www.imidaily.com
