Article in the New York Times.
Note final sentence in the quote below.
“Next year, Washington will enact [sic] the most ambitious tax-recovery plan in history, the Foreign Account Tax Compliance Act. Under Fatca, foreign financial firms will have to proactively identify every American account holder with assets of more than $50,000 and report details about their financial activity or face a significant penalty. The move is very unpopular among foreign banks, governments and Americans living abroad, but the more complex rules could actually mean more business for offshore centers. By the time Fatca is in full force, in 2017, truly wealthy individuals and corporations will almost certainly have used their resources to find more intricate loopholes.”