Regulatory Information

AML Program Letter

IRS Foreign Account Tax Compliance Act (FATCA) Notice

The Foreign Account Tax Compliance Act (FATCA) is a US law designed primarily to identify, and disclose the identity of, specified US persons—both individuals and entities—who hold financial assets and accounts outside of the US through foreign financial institutions, nonfinancial entities, or other investment structures. Since the income from such assets may be subject to US taxation, FATCA generally requires foreign financial institutions and other entities to identify and subsequently report the accounts of specified US persons.

Intergovernmental agreements (IGAs) between the US and many foreign jurisdictions facilitate the exchange of this information and address local bank secrecy and privacy issues that may exist. Failure to comply with FATCA can lead to the implementation of a 30% withholding tax on payments made to noncompliant parties.

When opening a new account, Banking Circle US may request additional information and documentation from clients to determine the account holder’s FATCA status, and for purposes of identifying specified US persons that may have an ownership interest in the account.