IPRs: The Story Continues…

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...
Joining the Compliance Dots: Periodic Reviews

Joining the Compliance Dots: Periodic Reviews

Joining the Compliance Dots: Periodic Reviews The most common comment I’m hearing these days about FATCA is that the compliance pressure is off now that the deadlines for due diligence are past. Well, as is common in financial circles, this is both inaccurate,...