The US Qualified Intermediary (QI) and Foreign Account Tax Compliance Act (FATCA) are now considered business as usual. The designated Responsible Officer (RO) is required to periodically certify the compliance of his or her organisation with these regimes. The RO should take a step back now to consider the needs of his or her institution and how best to position it for the upcoming certifications. Further, financial institutions will be required to demonstrate the adequacy of the internal reporting/interaction between the executing functions and the senior management to enable informed compliance certifications.
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