For FATCA – a specified US person is reportable. This includes US residents, citizens, and green card holders. They will be reportable if they own a financial account in a FATCA partner jurisdiction or if they are substantial owners or controlling persons of a Passive NFFE.
For CRS - unlike FATCA, the CRS does not require financial institutions to report on citizens or nationals but focuses on tax residency. Under the CRS, an individual identified by a financial institution established in a CRS participating country, as a tax resident in another CRS country, would be reportable to that other CRS country. This includes taxpayers who are identified as controlling persons of a Passive NFFE.