The FATCA US regulations, the IGA’s and the CRS are prescribing several due diligence procedures. These obligated due diligence procedures are not that equal for Banks, Fiduciary Corporate Director and Insurance Companies. We provide advice on the interpretation, explanation and processing of the several due diligence steps to be followed and performed by Financial Institutions. For example in relation to, among others;
- dormant accounts
- joint accounts
- undocumented accounts
- controlling persons
- substantial US owners
- entity classifications (holding companies, investment companies,
- trust if these are FIs, A-NFEs or P-NFEs)
- Multiple residency FI’s
- Non reporting FI’s
- Sponsoring procedures
- Reporting procedures
- Treatment of Pre-existing versus New Accounts
- Entity classification conflicts with Banks