South Africa signed an Intergovernmental Agreement for FATCA compliance with the U.S on 9 June 2014 (“SA IGA”), making South Africa an IGA Jurisdiction, effective 1 July 2014 . The SA IGA requires impacted South African financial institutions to identify all clients in line with the client due diligence requirements stipulated in the SA IGA and to (amongst other things) report certain specified information on certain clients the South African Revenue Services (“SARS”) on an annual basis.
A failure to comply with the requirements set out in the SA IGA will result in a breach of South African law. As such, it is imperative that South African Financial Institutions take steps to assess their SA IGA impact.
With the first effective date for the SA IGA recently having passed, it is imperative that impacted South African Financial Institutions prioritise their FATCA implementation project. To this end, we have set out a few questions in light of the SA IGA for Boards to consider.
If you are unsure about the impact on the Financial Institution, or should you assess that you are impacted, we recommend taking advice on this sooner rather than later to avoid any associated risks.
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