FATCA policy

The US Foreign Account Tax Compliance Act (FATCA) affects you if you are a so-called US person (US citizen or US-based entity). United must determine whether you meet the criteria, and if so, we must report your account information to the US tax authorities. United performs these duties quickly, expertly and with minimum disruption to your affairs.

General information

FATCA stands for the Foreign Account Tax Compliance Act (FATCA), which was enacted as part of the Hiring Incentives to Restore Employment (HIRE) Act in the United States on 18 March 2010. FATCA is a US law introducing registration and reporting obligations for non-US entities, the aim of which is to identify and collect the appropriate amount of tax from all US persons holding financial assets outside the US. FATCA legislation has been written specifically in order to address the avoidance of tax by US persons through foreign financial institutions. FATCA legislation potentially applies to any company or entity with US clients or assets that could generate income sourced in the US.

FATCA Compliance statement

The Bank is in absolute compliance with the US Foreign Account Tax Compliance Act, as established by US Congress and enforced by the Department of the Treasury’s Internal Revenue Service. The Bank already had in place extensive Know-Your-Customer and Customer Due Diligence policies and procedures. These policies and procedures have been thoroughly reviewed and updated where needed in order to ensure full compliance with FATCA requirements.

Specific client acceptance procedures to ensure FATCA compliance

As part of the client acceptance process within the bank, any new client is required to fill out and sign a FATCA statement. This FATCA statement contains questions to verify whether a new client should be defined as a US person according to FATCA regulations. Such a statement is to be completed and signed by all new private (individual) clients.

A similar procedure applies for United’s non-US corporate clients. When a new corporate client is onboarded, we request and file valid IDs of all ultimate beneficial owners (UBOs) with more than 10% ownership, and ask them to complete and sign a FATCA statement.

This procedure, along with the existing KYC/CDD procedures, ensures that the bank makes every reasonable effort to identify, and hence report, US persons within its client acceptance process.