The latest version of the Crown Dependency Guidance Notes to FATCA, which was released on 28 July 2014, has provided further changes to, and clarifications of, the obligations of Jersey Financial Institutions in respect of FATCA.
As the States of Jersey has entered into two intergovernmental agreements (“IGAs”), one with the US, and the other with the UK, Jersey Financial Institutions must take steps to understand their obligations under each of the IGAs.
With the first reporting to be completed by 30 June 2015, now is the time for Financial Institutions to put in place policies and systems, which are appropriate for their business, to ensure they are FATCA compliant ahead of the first reporting.