Offshore Account Without Automatic Exchange of Information (CRS): The Current 2026 Country List

The starting point

Anyone looking for a foreign account with a little more financial discretion quickly comes across the automatic exchange of information (Common Reporting Standard, CRS, known in Switzerland as AEOI). Around 120 countries now automatically exchange account data with the tax authorities of other countries. A handful of jurisdictions still do not participate – and the list has changed noticeably over the past two years.

As SWICOR (Swiss Corporate Solutions Ltd.) we support the remote opening of bank accounts, including in Georgia and Cambodia.

What CRS is – and why an unreported account must still be declared correctly

The OECD's Common Reporting Standard requires participating countries to automatically report account data of foreign taxpayers to their country of residence. An account in a country that does not participate in CRS is therefore not automatically reported. That is a real, legal difference from an account in a CRS participating country.

However, this does not change your own declaration obligation. Anyone living in a country with residence-based taxation remains obliged to declare foreign accounts and income correctly under local rules – regardless of whether automatic reporting takes place. An account without CRS reporting reduces the risk of detection in case of non-declaration, but it does not make non-declaration lawful.

Legitimate reasons for an account in a non-CRS country are above all access to a stable, diversified banking system outside your own currency or legal area, protection against capital controls and account freezes, and access to financial products not available at home.

The countries that really do not participate in CRS in 2026

As of summer 2026, the better-known non-CRS countries relevant to international entrepreneurs include:

According to the OECD, numerous other countries less relevant to most European entrepreneurs are also non-participants, such as Paraguay, El Salvador, Cape Verde and several African states.

Important correction: Georgia and Armenia are no longer non-CRS countries

This is the most important update compared with older country lists from 2023/2024 that are still circulating online: Georgia has transposed the CRS standard into national law, completed due diligence on time and went through its first full reporting cycle in 2024 (2023 data was exchanged). Armenia has also started the automatic exchange of information, with a first data exchange from 2025.

Cambodia in detail: currently the most robust non-CRS location

Of the remaining non-CRS countries, Cambodia is currently particularly interesting for international entrepreneurs: over recent decades the country has seen remarkably stable economic development without a major recession, has a heavily dollarised banking sector (most accounts are held directly in US dollars) and hosts, alongside local banks, branches of international and regional institutions, particularly from Malaysia.

Important caveat

Cambodia generally taxes tax-resident individuals on their worldwide income. The absence of CRS participation must therefore not be confused with tax neutrality, especially if tax residence is actually established in Cambodia. For simply holding an account as a non-resident this is usually not directly relevant, but it should be kept in mind if an actual relocation of residence is planned.

Traditional in-person account opening usually requires a longer-term residence permit in addition to a passport and is subject to varying minimum deposits – without a residence permit of several months and local proof of address, regular in-person opening is hardly possible in practice. Through a specialised service such as SWICOR, however, the process can be handled remotely.

Georgia remains attractive – but for other reasons

Even after joining CRS, Georgia remains an interesting banking location – not because data is not shared, but because of:

• ✛comparatively simple account opening, still possible remotely, which sets Georgia apart from many other countries on this list,
• ✛a solid banking landscape with internationally recognised institutions such as Bank of Georgia and TBC Bank, which show good capital and earnings figures by regional standards (see our banking comparison of Switzerland, Liechtenstein and Georgia),
• ✛attractive interest rates on foreign-currency balances compared with many Western European banks,
• ✛its geographical position as a bridge between Europe, the Middle East and Central Asia.

Georgia therefore remains well suited as a building block of a diversified but fully declared international account structure – not as a discretion solution.

New since 2026: CARF and crypto reporting

A point naturally missing from older country lists: since 1 January 2026 the EU has been implementing the OECD's Crypto-Asset Reporting Framework (CARF) via the DAC8 directive – a CRS-like reporting mechanism specifically for crypto assets and crypto service providers. Most major economies within the OECD and the EU intend to implement CARF by 2026/2027.

Notably, the United States is among the countries that have not committed to CARF so far, relying instead on FATCA and its own domestic crypto reporting rules. Anyone planning international structures for digital assets as well should keep this development in view alongside the classic CRS landscape.

Practical tip: keep an eye on the FATF lists

Beyond the CRS question, it is worth looking at the Financial Action Task Force (FATF) country lists: countries on the FATF blacklist (currently including Iran, North Korea and Myanmar) are effectively cut off from international SWIFT payments. Countries on the FATF grey list often trigger much more intensive checks at correspondent banks, delayed transfers and repeated questions about the source of funds.

A country may formally not participate in CRS but be practically unusable due to FATF-related payment problems. Pure discretion without functioning payments is of little help to most entrepreneurs.

How SWICOR supports you

As SWICOR, a brand of Swiss Corporate Solutions Ltd., we accompany you with remote account opening in both Cambodia and Georgia – two locations with different but clear value propositions: Cambodia for genuinely absent CRS reporting combined with your own declaration in your country of residence, Georgia for a stable, accessible banking location with simple account management.

We also support remote opening of a US account and help assess which combination of corporate structure and banking suits your personal situation.

Conclusion

• ✛Around 120 countries now participate in CRS – the number of practically usable non-CRS countries for serious international banking keeps shrinking.
• ✛Georgia and Armenia have not been non-CRS countries since 2024/2025 – an important correction to older country lists.
• ✛Cambodia is currently among the most robust remaining non-CRS locations, with a heavily dollarised banking sector and stable economic development.
• ✛The absence of CRS reporting does not release you from your own declaration obligation in your country of residence – an unreported account is a building block for more discretion, not a licence for tax evasion.
• ✛Since 2026, CARF/DAC8 extends reporting to crypto assets – an additional factor for anyone also structuring digital assets.

Frequently asked questions