FATCA Compliance

We recognize global movements to widen tax regimes across borders such as the enactment into law by the United States government of the Foreign Account Tax Compliance Act. We also value our ability to promote greater international tax transparency and discourage tax abuses and, in support, have a FATCA Compliance unit to ensure the consistent and effective compliance with FATCA regulations throughout the bank and its subsidiaries.



A significant number of countries worldwide  have signed the Inter-governmental Agreements (IGAs) relating to FATCA compliance with the United States government. These IGAs will result in the FATCA legislation becoming part of these countries’ local laws. Governments that have signed a Model 1 Intergovernmental Agreement (IGA) with the US have implicit and explicit responsibilities to enable their local Financial Institutions (FIs) to comply with the Foreign Account Tax Compliance Act (FATCA). A Model 1 IGA requires the competent authority or its delegate to collect account holder information, perform a data quality check on the data and then submit consolidated information of certain clients to the Internal Revenue Service (IRS) in a secure manner. On an annual basis, Banks and other Financial Institutions will be required to report information on financial accounts held directly or indirectly by US Persons.



As required under the rules of FATCA, we have appointed a responsible officer to oversee the bank’s compliance with regulations and establish a program to ensure its effective implementation. Our FATCA compliance program provides for additional requirements on customer due diligence and documentation and new reporting guidelines to the relevant tax authorities.



The Bank appears in the U.S. internal revenue service official list of participating financial institutions with the bank’s Global Intermediary Identification Number (GIIN) of CUC04I.00000.LE.608.



Type of Financial Institution (FI): Lead of an Expanded Affiliated Group



FATCA Classification and Date of Registration:

  • Participating Foreign Financial Institution:  April 23, 2014
  • Registered Deemed-Compliant Financial Institution/Reporting Financial Institution under a Model 1 IGA: March 23, 2015


Frequently Asked Questions


1. Who is affected by FATCA?

FATCA legislation will affect both personal and business customers who are treated as a ‘US Person’ for US tax purposes. The FATCA legislation will also affect certain types of businesses with US owners. The term US person includes the following (but is not limited to):

  • A citizen of the US, including an individual born in the US but resident in another country (who has not given up their US citizenship)
  • A person residing in the US, including US green card holders
  • Certain persons who spend a substantial number of days in the US
  • US Corporations, US Partnerships, US estates and US trusts


2. How will FATCA be applicable to BPI’s personal or business customers?

FATCA legislation will impact both personal and business customers who hold a deposit, custodial, or investment agreement with BPI.*

*It also covers cash value and annuity contract of BPI subsidiaries.



3. Am I only affected if I am a BPI customer who is a citizen of the US?

No. If an individual’s account holds any of the following seven (7) criteria, BPI may request further information/documentation to determine if you are a US Person under FATCA.

  • US citizenship or US residence
  • US place of birth
  • US address including US PO boxes
  • US telephone number
  • Repeating payment instructions to pay amounts to a US address or an account maintained in the US
  • Current Power of Attorney or signatory authority granted to a person with a US address
  • In Care of or Hold mail address which is the sole address for the account holder


If you are considered a US Person, you may be asked to supply BPI with additional information/documentation.. If you are a specified US Person, BPI will be required to report information about you and your account to the local tax authority (Bureau of Internal Revenue) on an annual basis. While we will correspond with affected customers in due course, BPI cannot offer any advice relating to FATCA and we recommend you contact a professional tax advisor to discuss your personal tax situation.


4. What does FATCA mean for me if I am not a US Person?

For most customers, FATCA will have minimal impact, and there will be no action required. However, BPI may still contact you to confirm your status as a non-US person. New Accounts clients, however, should submit a self-certification even if not a potential US Person.



5. What do I need to do if I am a business customer of BPI?

In order to establish your tax status under FATCA, the bank may need you to provide additional information/documentation. This documentation could be a BPI declaration and/or a US tax form from the IRS.



6. What information/documentation is needed by BPI for FATCA purposes?

The information or documents needed will depend on the FATCA classification of the customer. This information will typically be of a personal nature in relation to the controlling US owners of a business (for example, Name, Address, US Taxpayer Identification Number), and of a financial nature (e.g. Account number, Account balance/Value). Documents may include US tax forms (also referred to as withholding certificates or W forms) or self-declarations of FATCA status.



Forms can be downloaded below:
W-8 BEN E (June 2016 version).