There are a number of jurisdictions around the world whose Foreign Financial Institutions (FFIs) are not required to undertake FATCA reporting and are not subject to the FATCA “stick” of withholding. In total, there are 22 jurisdictions that have a Model 1 Intergovernmental Agreement (IGA) signed but not in force or are treated as having a Model 1 agreement in substance. The result is that almost 11,000 FFIs that have registered for GIINs have not been required to report U.S