This paper follows on from our recent article ‘No Low FATCA diet for UK Insurers’ and discusses some of practical FATCA considerations, such as the impact on investments, policy documentation and personal pensions, and areas to discuss further with industry bodies. We suggest that now is the time to start:
- Updating investment mandates, so once FATCA goes live investments in non-participating FFIs are not permissible;
- Liaising with your legal team to consider possible changes to policy terms and conditions; and your risk function to update KYC/AML procedures for taking on new policyholders.
Remember the regulations are still draft so discuss your concerns directly with the IRS or with your industry body.
KPMG will continue to share its views with the IRS on the implications of FATCA on the UK insurance industry. Should you have any questions on how your business might be affected, or require assistance with your FATCA project, please contact your usual KPMG contact or one of our subject matter experts listed.
