Financial Institutions (FIs) around the world find themselves with terminated FATCA accounts. As a result their Global Intermediary Identification Numbers (GIINs) have been removed from the IRS FFI List and counterparties consider them to be Non-Participating Foreign Financial Institutions (NPFFIs). The costly outcome is that these FIs are subject to FATCA withholding. Although the IRS established a reinstatement process, the process is not working. FATCA Withholdable Payment

Certain entities may register in the IRS FATCA portal and, upon registration approval, receive a Global Intermediary Identification Number (GIIN). For some entities, the FATCA portal registration process involves the entity entering into an FFI Agreement with the IRS and submitting certain certifications. If the entity fails to submit these certifications, their IRS FATCA account may turn from Approved to Terminated. But you can reverse this status! IRS FATCA Certifications

On March 23, 2022, the U.S. Internal Revenue Service (IRS) posted a new question and answer on its FATCA – FAQs General site: Q22. How do I submit my FATCA certification if the registration status has been changed to under review with a message indicating “For more information contact the Treasury Department Office of Foreign Asset and Control (OFAC)”? If you have a FATCA certification due, and your registration status has been changed to under review with a message informing

If you missed the July 1 deadline for submitting a FATCA Responsible Officer (RO) Periodic Certification, the Internal Revenue Service (IRS) may change the registration status of your Foreign Financial Institution (FFI) to “Agreement Terminated”. This will result in your FFI’s Global Intermediary Identification Number (GIIN) being removed from the IRS FFI List. GIIN Removal An important aspect of registering an FFI in the IRS FATCA portal is obtaining a GIIN. For those partic