FATCA and the UK legislation implementing the Agreement signed on the 12th September 2012, applies to Financial Institutions located in the UK. In the Agreement and in this Guidance these are referred to as “UK Financial Institutions”. In order to determine how the legislation applies it will be necessary for a Financial Institution to consider a number of questions, namely:
Am I a Financial Institution?
Do I maintain Financial Accounts?
Are there indicators that any of the account holders’ are Specified US Persons?
After applying the relevant due diligence, do I have any Reportable Accounts?