More than 120 jurisdictions are described as participating in the Common Reporting Standard, a system that automatically exchanges financial account information with a person’s tax authority. A smaller group of countries remains outside automatic CRS exchange, and several of them offer residency or citizenship routes that may be relevant for people assessing banking privacy, tax residence, and jurisdictional diversification.
How CRS works
The Common Reporting Standard was created by the OECD in 2014 to reduce banking secrecy worldwide. Under CRS, a bank identifies where an account holder is tax resident and reports information to that jurisdiction’s tax authority automatically once a year.
Reported information can include:
- account holder name
- account balance
- yearly interest
- dividends
The reporting happens automatically, without a court order or prior notice to the account holder.
More than 120 jurisdictions are described as operating under CRS, with additional countries joining over time. Thailand, Kenya, Ukraine, and Armenia are cited as countries that began exchanging information within the last two years.
The key practical point is that CRS reporting is based on tax residence, not simply where a person banks. Getting residency in a non-reporting country may not change reporting obligations if the person remains tax resident in a CRS jurisdiction.
Serbia
Serbia is described as being on the OECD list of developing countries not asked to commit to CRS. For now, bank account information held in Serbia does not automatically flow outward under CRS.
The main caveat is Serbia’s European Union candidate status. Candidate countries tend to align with European transparency standards as they move toward EU membership, so Serbia’s current CRS position should be treated as tied to its accession timeline rather than as permanent.
Residency routes mentioned include:
- real estate purchase with no fixed minimum investment
- residential or commercial property allowed
- temporary residency possible within 30 to 60 days
- company formation route requiring around €50,000 held in a Serbian bank account
The route can lead to permanent residence after three years and citizenship after another three years.
Serbia is also described as having an E-2 treaty with the United States, giving Serbian citizens a separate route to U.S. residency.
Philippines
The Philippines is listed as a developing country not asked to commit to CRS, with no exchange date set.
Its banking sector is described as part of a substantial economy rather than a small offshore jurisdiction. The main route discussed is the newly designed FAB investor visa, or FIV, which grants indefinite renewable residency.
The FIV requires a $75,000 investment in:
- securities listed on the Philippine Stock Exchange, or
- a qualifying local enterprise in the Freeport area of Baton, unclear
A separate route is the Special Investors Resident Visa, written in the transcript as “SIRIRV,” unclear. It covers a wider range of qualifying investments.
Neither route is described as requiring physical residence in the Philippines. Residency remains valid as long as the investment is maintained.
United States
The United States never joined CRS. Instead, it operates FATCA, the Foreign Account Tax Compliance Act, which requires foreign banks to report U.S. account holders overseas to the Internal Revenue Service.
The distinction made is that the United States collects information on its own citizens abroad but does not reciprocate in the same way CRS jurisdictions do. For non-Americans banking in the United States, accounts are described as generally falling outside automatic exchange.
The caveat is important: this privacy applies to non-Americans banking in the U.S., not to U.S. citizens or residents. FATCA is designed to track Americans domestically and internationally.
The residency route mentioned is the EB-5 immigrant investor program. It offers a green card for a qualifying investment in a U.S. business that creates at least 10 jobs.
Investment thresholds stated:
- $1 million standard minimum
- $800,000 for a project in a targeted employment area
EB-5 provides residency, not immediate citizenship. A green card can lead to naturalization through the normal path after five years.
Bolivia
Bolivia is described as outside CRS and as not having adopted the newer crypto asset reporting framework. It is also described as having no FATCA agreement with the United States and being outside the OECD base erosion framework.
The cheapest route mentioned is a one-year temporary visa based on sufficient funds. Requirements stated:
- roughly $4,800 in available funds, or
- about $400 in monthly income
- no investment required
Another route is a three-year temporary visa through a Bolivian company. Company formation is described as taking one to two weeks.
After three continuous years, permanent residency and citizenship are both described as options.
Bolivia is also described as having a territorial tax system. Citizenship is said to carry “Merkasaur” settlement rights across nine South American countries, unclear.
The main caveat is banking friction. Bolivia is described as having landed on the Financial Action Task Force grey list in June 2025, which means international banks may scrutinize Bolivian accounts more heavily.
Egypt
Egypt appears on the OECD “not asked to commit” roster, with no exchange date set. Account information held in Egyptian institutions is described as not currently flowing outward automatically.
The caveat is that Egypt’s status is described as administrative rather than ideological, meaning it could change if the OECD’s approach toward the region changes.
Egypt has a direct citizenship program established in 2019. Four routes are described:
- $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 residency requirement for the citizenship routes. Egypt also has a residency by investment program, but it is described as having no path to citizenship.
Cambodia
Cambodia is listed as a jurisdiction not asked to commit to CRS, with no exchange date set. It is described as having appeared on advisory short lists of non-reporting banking jurisdictions, although account opening has tightened as global compliance pressure has increased.
Cambodia is described as having the only citizenship by investment program in Southeast Asia. The program traces back to the 1996 law on nationality, which waived normal residence and language requirements for qualifying investors and donors.
The transcript says investment thresholds rose in early 2026 after rumors in late 2025. The donation required for direct citizenship is now described as around $1 million, up from $245,000.
Citizenship is typically granted within about six months, with no prior residency required. Cambodia permits dual nationality.
El Salvador
El Salvador is described as being on the “not asked to commit” list and as having no FATCA agreement with the United States. This combination is presented as making it one of the more clearly non-reporting jurisdictions in the Western Hemisphere.
Its 2024 decision to exempt all foreign-source income from tax is described as strengthening its appeal from a tax perspective.
The main route mentioned is the Freedom Passport, which grants immediate citizenship in exchange for a $1 million investment in Bitcoin or U.S. dollars.
The program is described as expensive and therefore limited to a narrow group of applicants, but fast. Citizenship is described as typically available within three months.
Paraguay
Paraguay is described as the main outlier. It is not on the “not asked to commit” roster, but its account information still does not automatically flow outward under CRS.
In April 2026, Paraguay launched the Investor Pass, granting direct permanent residency without a temporary residency stage.
The three stated routes are:
- $150,000 in a qualifying tourism project
- $200,000 in Paraguayan real estate, requiring $60,000 upfront
- $200,000 in securities on the Asunion Stock Exchange, unclear spelling
The older SUACE route is also described as still available. It requires roughly $70,000 in business investment with local job creation.
Paraguay’s appeal is described as a combination of:
- low residency by investment threshold
- territorial tax system
- no tax on foreign income
- three-year path to citizenship, provided the applicant creates ties to the country and society
The caveat is CRS risk. The OECD treats Paraguay as a jurisdiction of relevance for future CRS adoption, so its non-reporting status may be less secure than some other countries on the list.
Practical considerations
The main lesson is that CRS depends on tax residence. Banking in Serbia or the Philippines while remaining tax resident in a CRS country may change little about what foreign banks report.
The jurisdictions described as most disruptive to automatic reporting are those that combine non-reporting status with a territorial or zero-tax system. Paraguay, Bolivia, and El Salvador receive particular attention for that reason, although each has drawbacks.
Key decision factors include:
- whether the country participates in CRS
- whether it has a FATCA agreement with the United States
- whether it taxes foreign-source income
- whether residency or citizenship is realistic
- whether banking access is practical
- whether current non-reporting status is likely to change
- whether the person actually changes tax residence
Non-reporting banking status alone is not enough. The practical effect depends on where the person is tax resident, how the country taxes foreign income, and whether the jurisdiction’s current CRS position is stable.
