7 countries that do not share your financial information under CRS: where to apply for residency or citizenship

In 2014, the OECD launched the Common Reporting Standard (CRS) to curb offshore banking secrecy and reduce tax evasion. Today, CRS is implemented in more than 120 jurisdictions. As a result, banks identify account holders who are tax residents of other countries and report relevant information to the appropriate tax authorities.

The data typically includes name and address, tax identification number, account balances, plus annual figures for interest, dividends, and income from certain transactions. Reporting is generally automatic and usually happens once per year. A government request or court order is typically not required, and account holders are often not informed what was sent or where it went.

The network keeps expanding. In recent years, countries such as Thailand, Kenya, Uganda, Moldova, Ukraine, and Armenia have joined the reporting framework, helping to close gaps that once attracted investors seeking privacy. At the same time, the list of jurisdictions still not covered by automatic exchange is shrinking—and the reasons differ from one country to another.

Important: this is not a guide to hiding assets. CRS status does not remove your tax obligations in your country of tax residence. Also, “not reporting” rarely means “invisible”—especially when you consider tax residency rules and how foreign banks apply their own compliance checks.

Below is an overview of where automatic CRS exchange is currently not in effect (based on OECD materials on AEOI obligations), along with the main routes to residency or citizenship available in each jurisdiction mentioned.

United States (USA)

CRS status: The United States does not participate in CRS and it’s not doing so quietly. Instead, it operates under FATCA (Foreign Account Tax Compliance Act), which requires foreign financial institutions to report information about U.S. taxpayers to the IRS.

A key point is asymmetry: the U.S. receives information about its citizens abroad, but does not exchange under CRS in the same multilateral way as participating countries. For a non-U.S. person who opens an account in the U.S. and is not a U.S. tax filer, CRS-style reporting usually does not apply.

In practice, that makes the U.S. one of the largest jurisdictions where “non-CRS-style” financial reporting is the norm—at least for now. Major changes are not obvious, because FATCA acts as a political and regulatory alternative to multilateral exchange.

Investment route: the EB-5 program (Immigrant Investor Program) can lead to a green card if you invest in a U.S. commercial enterprise that creates at least 10 jobs.

Typical minimum investment is around $1 million, and for projects in a Targeted Employment Area it is often $800,000. This is primarily a path to residency, not citizenship immediately—but a green card can later enable naturalization in the standard timeline (typically after several years).

Egypt

CRS status: Egypt appears on the OECD list of developing countries not invited to take on commitments, and the first reporting start date has not been set.

For now, account information held by Egyptian institutions is not automatically transmitted to other tax authorities. This is more of an administrative position than an ideological one—meaning it could theoretically change if the OECD revises its stance for the region.

Investment route: Egypt is one of only two countries in this category that offers a direct path to citizenship.

The Citizenship by Investment program, in place since 2019, provides four options: a non-refundable $250,000 contribution to the state treasury; real estate purchase for $300,000 with a 5-year holding requirement; a $350,000 business investment combined with a $100,000 donation; or a refundable $500,000 bank deposit returned after 3 years.

All options include a $10,000 government fee, and no stated residency requirements are announced.

El Salvador

CRS status: El Salvador is also on the OECD list of countries not invited to commitments and does not have a FATCA agreement with the U.S.

Taken together, these factors make the jurisdiction one of the most “lightly reported” in the Western Hemisphere. The situation is reinforced by a 2024 decision: in the country, all foreign-source income is exempt from taxation.

Investment route: the central program is Freedom Visa. It provides residency first, followed by an accelerated route to citizenship if you invest $1 million in Bitcoin or U.S. dollars.

The high threshold limits the applicant pool, but it remains one of the few cases where a right to citizenship can be obtained relatively quickly if funds are available.

Serbia

CRS status: Serbia is included on the OECD list of countries not invited to take on commitments. At the same time, it is an EU candidate country. In practice, candidate states usually align gradually with European standards on financial transparency—so “non-reporting” under CRS is better viewed as a function of the integration stage rather than a permanent model.

Investment route: Serbia’s investment visa is often considered one of the more accessible options in Europe from an entry-mechanics perspective. Real estate has no fixed minimum threshold: you can buy a residential or commercial property anywhere in the country and then obtain temporary residency, typically within 30–60 days.

There is also a route through company formation, which usually involves an amount around ~€50,000 held on a Serbian bank account.

Residency can then lead to permanent status after 3 years, and citizenship after another 3 years. Serbia also has an E-2 treaty with the U.S., giving Serbian citizens an additional path to U.S. residency.

The Philippines

CRS status: The Philippines are marked by the OECD as a developing country not invited to take on commitments, and the exchange start date is not set. Still, the country has a meaningful economy, which matters: the absence of exchange here appears tied more to how the banking sector operates than to “micro-offshore” characteristics of specific financial hubs.

Investment route: the Special Investor’s Resident Visa (SIRV) offers indefinite renewable residency in exchange for $75,000 invested in securities listed on the Philippine Stock Exchange or into an eligible local business.

There is also a separate Foreign Investor Visa for a broader range of investments. For both programs, you typically do not need continuous physical presence, and SIRV remains valid as long as the investment is maintained.

Cambodia

CRS status: Cambodia is listed by the OECD as not invited to take on commitments, with the exchange start date left uncertain. For a long time, the country appeared in advisory shortlists as a jurisdiction with “non-reporting” banking. However, as global compliance standards tightened, requirements for opening accounts and documentation have become noticeably stricter.

Investment route: Cambodia is the only country in Southeast Asia with an investor citizenship program—meaning it represents the “citizenship first” option within this list. The pathway is rooted in a 1996 nationality law, which historically allowed investors and donors to waive certain standard residence and Khmer-language knowledge requirements.

In December 2025, thresholds were raised substantially: you need $1 million invested in an approved project in a priority sector, or $3 million as a cash donation to the national budget. Citizenship is typically processed in roughly about 6 months, usually without a prior residence requirement. Cambodia also permits dual citizenship.

Paraguay

CRS status: Paraguay is a special case. It is not listed by the OECD as not invited to commitments, yet account data is not currently automatically exchanged with other states—so in practice the jurisdiction operates outside the CRS exchange mechanism.

The OECD treats Paraguay as a jurisdiction of interest for future CRS implementation. That makes its “no exchange” status among these seven countries the least stable.

Investment route: in April 2026, Paraguay launched the Investor Pass program, offering direct permanent residency without a temporary-residency stage via one of three routes: $150,000 in an eligible tourism project; or $200,000 in Paraguayan real estate or securities on the Asunción Stock Exchange.

Alongside this, there is an older scheme called SUACE, which typically involves about $70,000 invested in a business and creating local jobs.

Key advantages include a comparatively low threshold, a territorial taxation model (foreign-source income may not be taxed), and one of the shortest citizenship paths in the region—around three years.

What this list really tells you

Four of the seven countries offer a passport, not just residency. Egypt, North Macedonia, and Cambodia provide investor citizenship directly, while El Salvador has an accelerated route via Freedom Visa.

This distinction is crucial to understanding the list’s real-world meaning. CRS focuses on where you are a tax resident, not on where your money sits in a bank. For example, obtaining residency in Serbia or the Philippines while keeping tax residency in a CRS-participating country often changes little—because foreign banks still rely on your tax-residency status for compliance checks.

In reality, data flows are most “disrupted” in places where non-reporting is paired with a territorial or zero/low taxation model. That’s why Paraguay and El Salvador attract disproportionate attention, despite their limitations and risks.

This article is not tax advice. You should not treat it as a way to bypass disclosure duties.

The legitimate purpose of using such jurisdictions is asset diversification, geopolitical hedging, and tax planning—strictly through lawful changes to your tax residency and a properly designed compliance framework.

The programs above are not always the only routes in each country. Many jurisdictions offer additional residency and citizenship schemes not described here. For the full picture, review the IMI Program Pages for each program and country.

Expert note (often overlooked): even where CRS reporting is absent or delayed, account opening and due diligence are still governed by local anti-money laundering rules and by banks’ internal “know your customer” policies. In practice, institutions may request tax residency evidence, beneficial ownership documentation, and source-of-funds explanations—then apply risk-based controls that can effectively limit how easily you can maintain anonymity. For high-net-worth applicants, this is why the “CRS gap” should be considered alongside bank onboarding friction, documentation standards, and how your tax residency is evidenced across jurisdictions.

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