Taking control of FATCA: Building effective internal controls and processes to promote compliance and certification

June 2013

Overview

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.

Contact us

Jeff Trent
Partner
Tel: +1 (646) 471 7343
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Dominick Dell'Imperio
Partner
Tel: +1 (646) 471 2386
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Scott Dillman
Principal
Tel: +1 (646) 471 5764
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Frank Serravalli
Partner
Tel: +1 (646) 742 7510
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John Gibson
Principal
Tel: +1 (202) 414 4691
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Alan Pisano
Tel: +1 (617) 530 7216
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Richard Inserro
Principal, PwC
Tel: +1 (646) 471 2693
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