International Financial Law Prof Blog
Last month, the GIIN list included 104,344, a jump from the September list of 5,000 from 99,861 FFIs (mind you that a substantial number of these registrations are not unique, but instead represent affiliates within EAGs) - see our previous analysis links below. It is now November. The UK self-imposed (yet ignored) deadline to GIIN register passed October 25th. So what happened?
As of October 27, 2014 GIIN registrations reached
116,104 FFIs! But - uh oh - not looking too good actually. A jump of 12,000 is as good as the past three months combined, so that's indicative that FATCA GIIN registrations may be moving toward an upswing. To reach at least a 50% level of FATCA compliance by year's end, the GIIN list must double in the next 25 days. Likely? Not based on the lack of support of many revenue authorities around the world (e.g. Turkey, India, China) that want to work out certain aspects and implementing regulations for the IGAs in place.
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