FATCA: Are we having fun yet?

Anyone who has been involved in designing, building, deploying or ultimately managing an anti-money laundering and counter-terrorism financing (AML/CTF Program) and has lived to tell the tale will agree on at least one thing – what appears to be relatively straightforward in theory is a great deal more complex to implement in practice, such is the diverse and multifaceted nature of financial service businesses today. Six years on – and with many reporting entities still refining, tweaking, re-designing and enhancing their AML/CTF Programs – these same bodies are staring down the barrel of a potentially larger and more complex compliance program called the Foreign Account Tax Compliance Act (FATCA).

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