If your FATCA certification period ends on 31st December 2021, your Responsible Officer certification is due no later than 1st July 2022.

If you do not submit your certifications by the due date, your firm will not be in compliance with its obligations under FATCA.

The consequences of being non-compliant may include the revocation of your firm’s FATCA status and, ultimately, your firm’s GIIN being removed from the FFI list.

Source: Internal Revenue Service, FATCA News & Information Issue: 2022-03