FATCA GIIN Timing Issues

Timing is everything in life and timing counts in obtaining a GIIN for FATCA. Poor timing can impact opening a bank account, submitting annual FATCA reporting, and more.

What Is a GIIN?

A Global Intermediary Identification Number (GIIN) is the identification number that the IRS assigns to an FI once the entity’s FATCA registration in the IRS FATCA portal has been approved. The GIIN serves the purpose of identifying the registered entity to withholding agents and tax administrators for FATCA reporting purposes.

To obtain a GIIN, an individual must use the FATCA Registration System. To read more about the registration process see my post: New IRS FATCA Portal Sign in Process.

Not an Instant Process

Once you have entered the necessary information into the IRS FATCA portal to create a new FATCA account, your GIIN will not be automatically issued. At the earliest, you will obtain the GIIN the following morning (U.S. ET) by logging back into the account. If you register your entity during the American weekend of Saturday and Sunday, you will need to wait until Tuesday morning (U.S. ET).

If you make the frustrating mistake of entering an entity name twice while registering several entities, you will wait up to 45 days for the IRS to conduct a review of the “Duplicate Registration”. This is the wait time even if you realize your error and change the name after submitting the registration request – and even if you reach a real person at the IRS to explain the simple mistake.

IRS FFI List

The IRS FFI List is also not an instant process. The GIINs generated by the IRS FATCA registration system are only updated on the FFI List once per month. The IRS has not always issued the FFI List on the same day of the month. Additionally, the FFI List is not current to the date the FFI List is published. When you are checking the FFI List for a particular GIIN, look just above the grey Search/Download FFI List box to see how current the list is. For example, the FFI List which was issued on May 1, 2025 states: “Financial Institutions in approved status as of April 24, 2025.”

Why is this important? Counterparties use the FFI List to validate the IRS W-8 forms and self-certifications that you complete. It is helpful to download a screenshot of the homepage of the entity’s FATCA account homepage to share with the counterparty to avoid delays in opening an account.

Foreign Portal Recognition of FFI List

Many non-U.S. jurisdictions require an entity to register for FATCA purposes in the jurisdiction’s own FATCA portal. Most of these portals will only allow you to complete the registration after the updated IRS FFI List has been published, the IRS has shared the IRS FFI List with the jurisdiction, and the jurisdiction’s own portal technology team has updated their portal to reflect the new IRS FFI List. Thus, we keep with the theme that none of the FATCA process is automatic.

For example, the Cayman Islands DITC requires the GIIN be on the published IRS FFI List prior to the DITC portal accepting a new registration. However, the Cayman Islands DITC portal does not automatically update its system as soon as the IRS FFI List is issued. As of May 20, 2025, the DITC portal will not accept a GIIN that was included on the IRS FFI List published on May 1, 2025. After attempting the registration, the DITC rejects the registration and notes:

“The GIIN you have entered does not appear in the current IRS FFI List. Please refer to this list and ensure the data has been correctly entered into the form. Note that this list is updated by the IRS monthly.”

Guernsey recently reminded IGOR users that IGOR will not accept annual FATCA reports unless the report includes a GIIN on the published IRS FFI List. The Guernsey Revenue Service alerted users that failure to obtain a published GIIN will not be accepted as a valid reason for delayed FATCA report submissions.

Next Steps

Frontload! Communicate with your colleagues to ensure you are getting information about the formation of new entities as soon as possible. Provide training to your colleagues so they understand the importance of your receiving the information so that you can classify the entity for FATCA and CRS purposes and, if necessary, obtain a GIIN.

For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.