IEIM402960 | Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Electronic Records Search FATCA Exemption

Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Electronic Records Search FATCA Exemption

A Financial Institution does not need to carry out the paper record search [see IEIM402940] for determining a person’s non-US status where it has retained a withholding certificate and acceptable documentary evidence [see IEIM404060].

Withholding certificates issued by the IRS such as the W-8 and W-9 series are acceptable in establishing an Account Holder’s status. A Financial Institution may rely upon a pre-FATCA W-8 form in lieu of an updated version of the form until such time that the W-8 is required to be renewed.