FATCA Compliance Services


Our FATCA services

Your FATCA implementation project and the range of services Deloitte has in place to support you.

FATCA compliance

Commercially, your entity cannot compete in the global market place if your clients suffer from a 30% withholding tax.

You will have to implement the systems and operations to adhere to disclosure, reporting and withholding obligations. Current account opening processes, transaction processing systems and know your customer procedures will be impacted. Proper compliance risk assessment should be addressed immediately to evaluate necessary modifications to existing systems, processes and procedures.

We propose the following services to assist our client in the implementation of FATCA compliance requirements. Depending on the scope of your activities project, FATCA compliance projects need a full set of tasks that need to be performed

Discover more about our FATCA tools and accelerators.

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FATCA implementation step by step

Step 1 - FATCA strategy

  • Classification of your entity under FATCA
  • Differences between your entity and other Group entities
  • Definition of your FATCA vision and high level business guidelines

Step 2 - FATCA impact assessment

  • Impact on client classification and client on-boarding, on your distribution channel(s), on your financial instrument database, and on your transactions
  • Reporting and withholding requirements
  • Requirements and impacts on your organisation

Step 3 - FATCA gap analysis, action list and roadmap

  • Definition of your target operating model
  • Definition of the gap and action list on client data related tasks and information to be added, on financial instruments static and period data, and on your transaction platform / core banking system
  • Client data quality assessment (in the context of FATCA), definition of the gap and action list
  • Definition of the action list for your organization; including resource training, new controls, new tasks to be covered within the organization, job description
  • Consolidation of action lists and definition of the FATCA implementation roadmap

Step 4 - FATCA implementation

  • Definition of the functional and technical specification on client and instrument systems and databases
  • Enrichment of client data quality
  • Enrichment of financial instrument static and periodical data
  • Definition of the functional and technical specification on your transactional systems / core banking systems
  • Assistance in the definition of test scenarios, in the execution of the tests, in the update of your procedures and job descriptions, in training your resources, and in updating GT&C or third party contracts

Step 5 - Reporting function

  • Industrialisation of your FATCA reporting functions
  • Synergies with tax reporting requirements for other jurisdiction’s

Regulatory FATCA hotline

  • Response to your questions
  • Analysis of specific cases along your project
  • Rapid access to latest updates and analysis

More information about FATCA regulation

We provide you more details about the FATCA regulation concerning:

  • Technical aspects of this regulation, like due diligence procedure, reporting requirements, withholding requirements, affiliated group requirement, and the “FATCA five”.
  • Impact of FATCA on banks, investment funds, real estate, PSFs, private equity and hedge funds.
  • FAQs on FATCA challenges and issues, both for all financial institutions or by specific industry.


Pascal Eber

Pascal Eber

Partner | Consulting–Banking, Insurance & Non-FSI

Pascal is a partner within the advisory and consulting department and has over 17 years of banking experience (front, middle, back-offices and IT) combined with his knowledge of consulting methodologi... More

Eric Centi

Eric Centi

Partner | Financial Services Tax

Eric is an expert in Operational Taxes where he assists financial institutions on topics such as: Aberdeen Tax Reclaims: Filing of withholding tax reclaims on behalf of investment funds on the basis o... More