CRS and Correspondent Banks

[pipona]

Forgive me if this has been answered elsewhere. I did a cursory search but couldn't find.
If someone has bank accounts in 2 non-CRS countries and wishes to transfer USD funds between them, but the wire goes through a bank in a CRS-country, is this detectable and reportable?

 

[OffshorePhantom]

Hello, in theory no since CRS reports account balance and not the transfers made.

Also the intermediary bank is only used to make the transfer and since you do not‌ have any accounts with that institution it does not have any obligation to report you‍ under CRS.

 

[Sols]

The correspondent account is held in the name of the bank, not in your name.‌ Accounts held by financial institutions are exempt from CRS.

As @hireblade89 says, reporting is based‍ on accounts, not transactions.

 

[Martin Everson]

Detectable naturally but not CRS reportable.