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 you to contact OFAC for more information, you will not be able to submit a FATCA certification at this time. Once the registration status is under review, you no longer have access to the periodic certification and certification of pre-existing accounts link.
If the account is placed back into registration approved status you will receive a message on your message board informing you of the registration status change to approved, and you will then have access to submit the applicable certification(s). If this occurs near or after the certification due date, you will be provided with additional time to submit your FATCA certification(s).
The IRS requires that some but not all Foreign Financial Institutions (FFIs) submit a Certification of Preexisting Account (COPA) or Periodic Certification. The consequences of being non-compliant may include the revocation of an entity’s FATCA status and, ultimately, the entity’s GIIN being removed from the FFI list.
The next scheduled deadline for certifications is July 1, 2022.
For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.
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