Given the information publicly revealed by “Panama Papers”, and recent IRS reminders to out-of-compliance US Taxpayers to come into full compliance with their federal tax obligations, it is critical that Bankers and Financial Institutions educate their clients regarding banking industry Customer Due Diligence (CDD) guidelines.

FATCA reporting exchanges took place in 2015 and 2016. When during a FATCA exchange of information, the existence of undisclosed reportable FATCA accounts is reported to IRS, US banks may find themselves with clients who have not informed them of previously undisclosed reportable offshore account(s).