IPRs: The Story Continues…

IPRs: The Story Continues…

I started this blog series from the premise that FATCA has control and oversight mechanisms consisting of two parts: a continuing obligation on the responsible officer (RO) to declare any events of default or material failure of control adequacy, and a three year...
Joining the Compliance Dots: Periodic Reviews

Joining the Compliance Dots: Periodic Reviews

FATCA due diligence deadlines are starting to pass so it is time to breath a big sigh of relief. Well, no. In this post, Ross McGill explains the FACTA control and oversight system and why Responsible Officers should be considering interim period reviews.