Due next on the FATCA Agenda

comment - 24 February 2015

Due next on the FATCA Agenda

FATCA due diligence and reporting

All entities should now have completed their legal entity classification and registration phase. Those which are classified as Reporting Financial Institutions (RFI) are now required to focus on customer due diligence and reporting.

Key dates in 2015

There are three key dates that RFI should be aware of in 2015:

+ 31 March 2015 – this is the first FATCA reporting deadline for RFI in non-IGA jurisdictions and RFI in Model 2 IGA jurisdictions;
+ 31 May 2015 (e.g. UK RFI) or 30 June 2015 (e.g. most other Model 1 IGA RFI) – these are the dates of the first FATCA reporting for RFI in Model 1 IGA jurisdictions; and
+ 30 June 2015 – this is when the review of pre-existing high-value individual accounts (over US$1m) must be completed.

RFI will need to report the US account information to the IRS or relevant tax authorities. It is important to note that the scope of reporting obligations will increase in 2016 and 2017.

Due diligence

RFI are allowed to use three processes in identifying their pre-existing account holders:

+ indicia search;
+ self-certification; and
+ publicly available information (for entities only).

During this process, however, it is important that RFI pay attention to embed the proposed requirements of Common Reporting Standard which will come into effect in 2016.


The RFI must report the identified reportable account holders and / or controlling persons (depending on the type of account) as well as the account number, balance or value as at the end of the 2014 reporting period.

RFI in some jurisdictions including the UK, Jersey and Guernsey can now register and submit reports on their reportable US accounts through their respective Automatic Exchange of Information portals:

+ Guernsey
+ Jersey
United Kingdom

We anticipate that similar portals will be launched in Luxembourg, the Netherlands and Sweden shortly.

previous comment / Udi Vithanage

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