The Internal Revenue Service have recently confirmed that under FATCA in order to be issued with a Global Institution Identification Number (“GIIN”) before the 1 January 2015 registration must be completed via the online portal no later than 22 December 2014.

This is important as any Foreign Financial Institution (“FFI”) resident in a Model 1 IGA countries such as Guernsey & Jersey, are required to be able to provide their GIIN to financial counter parties from 1 January 2015 onwards.

For those entities that have not yet decided how FATCA impacts them or whether they need to register should now do so as a matter of urgency as they may experience difficulties dealing with Banks, investment houses and other FFIs in the new year if they are unable to provide a GIIN.

This also includes being able to confirm a FATCA compliant status where no GIIN is