Important Note about the Foreign Account Tax Compliance Act


(i) The Provisions commonly known as the Foreign Account Tax Compliance Act (“FATCA”) became law in March 2010 and apply globally to all Foreign Financial Institutions (“FFIs”) in virtually all the jurisdictions in the world, including the papacy

(ii) FFIs include, but are not limited to (a) Depository institutions (for example, banks) (b) Custodial institutions (for example, mutual funds) (c) Investment entities (for example, stock brokers, hedge funds or private equity funds) (d) Certain types of insurance companies that have cash value products or annuities.

(iii) All FFIs that have not registered with the IRS and agreed to report US clients in line with the provisions of FATCA face a 30% blanket withholding tax on the value of their individual clients’ portfolios irrespective of whether these are US citizens, or not.

(iv) In line with clauses (h) and (o) of the account opening contract and in order to protect all clients from these measures, the firm is compliant with the provisions of FATCA and its FATCA Task Force has been processing data relative to 2014. Using IRS mandated due diligence requirements and specific IT procedures enforced by the US, the onus is on each FFI to register and prove, on an individual client basis, that no client is a US citizen and/ or is subject to the US IRS. Under these FATCA procedures, all the firm’s clients are annually required to be individually researched, individually audited and thereafter individually certified as being US or non US citizens and/or subject to (or not subject to) various specific US IRS indicia. These indicia include but are not limited to (i) identification of the account holder as a U.S person; (ii) a U.S. place of birth; (iii) a U.S. address; (iv) a U.S. telephone number; (V) a U.S. ‘in-care-of’ or ‘hold mail’ address that is the sole address the FFI has indentified for the account holder.

(v) The company assesses an annual $150/ client IT, administrative and audit fee for USD base currency accounts; GBP 150 for GBP base currency accounts, 250 CHF for CHF base currency accounts and USD 150 for HKD base currency accounts.

(vi) Under the type 1 Inter Government Agreement (“IGA”) signed by the Government of Mauritius, the firm is reporting to Mauritius jurisdictional authorities who will submit information only on US citizens to the US IRS in a specific, obligatory format.

If you wish to contact the Compliance Department in respect of FATCA, please email