Foreign Bank Account Reporting (FBAR): Navigating the Bends in the Road Mohan Murali, President, Axletree Solutions

What are others doing to comply? Today’s Agenda What is FBAR? Does it impact us / me? What are others doing to comply? Success Stories What are the tools available? Q&A

Report of Foreign Bank & Financial Accounts (FBAR) Established as early as 2003 Monitored and enforced Prevent incomplete disclosure of income. US Treasury Directive Enforced by IRS

Having Financial Interest Subject to FBAR Influence Outside of USA Bank accounts, Brokerage accounts, mutual funds, life insurance and more Trusts, Entities, Partnerships Controlled by U.S. citizens; U.S. residents; US entities, Having Financial Interest Influence, Control, Signatory Subject to Aggregate value of all accounts exceeded US$10,000

FBAR Influence Recordkeeping 5 Years Name maintained on each account. Account Number or identification. Name and address where the account is maintained. Type of account. Maximum value of each account

Qualify requirement against guidelines Penalties can be severe Does it impact us / me? Qualify requirement against guidelines Examples Penalties can be severe Negligent: $500 Non-Willful Violation: $10,000 Willful Failure or False Filing: Higher of $100,000 or 50% of balances Due June 30th for previous Calendar Year

Success Story Chicago Bridge & Iron Automated Controlled Accuracy

Industry – Heavy Construction CB&I Overview Industry – Heavy Construction Engineering and Construction Fabrication Services Technology Capital Services Size (Post 2013 Acquisition of The Shaw Group) $13 Billion 2014 Revenue $5.4 Billion Market Capitalization 55,000 employees Global view 150 + entities with accounts 600 + bank accounts 30 + banks

CB&I Needs & Challenges Acquisition Doubled the size of the company Transactions Partially centralized, partially decentralized (some project based) No treasury workstation 3 main challenges Bank account management and maintenance Daily snapshot of global consolidated cash balance FBAR compilation, distribution, and interface with IRS Solution needed connectivity to our banks and our worldwide users

CB&I Options and Solution In house solution Treasury Workstation Customized 3rd party solution Solution Selected: 3rd Party Solution Customized solution that maintains account database, Use that account information to prepare & file FBAR reports Connected via swift to our global banks Selected Axletree Selection Criteria Affordability Vendor who listened (not upsold) Functional expertise (Swift Certified Service Bureau)

CB&I Success and Future We achieved our mission and addressed our pain points Combined company could not use old tools Future Now have a platform for growth with global connectivity New functionality via Swift Payments? Open and Close accounts? Others? New database products Tracking of Bonds and Letters of Credit?

Tools Automated Reporting Tools Checks and Audits Accurate FBAR reports: Ready to submit

Solutions and Providers SaaS (Cloud) based solutions Integration with TMS Built over Bank Account Management Minimal setup, quick turnaround Consultancy services

Thank You