Most organizations implementing FATCA are currently focused on addressing core requirements around due diligence, withholding and reporting. However, leading organizations are simultaneously working to address governance, compliance and controls frameworks. Early “lessons learned” from such governance activities indicate that the level of complexity to implement controls will be significant, the controls and sub-certification framework will likely be multi-dimensional (e.g., by function, business unit, and geography) and the FFI Agreement certifications by the Responsible Officer will require significant coordination and communication across the enterprise. In our view, institutions should focus on designing a compliance and controls framework concurrent with the core FATCA implementation effort.
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