Last Wednesday, the IRS released the latest version of its database of GIINs for Foreign Financial Institutions, updated to 24 June. It contains 87,993 entries, up by only about ten thousand from last month. This minor increase doesn’t exactly look like a vote of confidence by the financial sector, especially when compared to estimates of hundreds of thousands of entities that might fall under FATCA’s definition of FFIs.
Furthermore, poorer countries are falling behind (not that the U.S. cares about the collateral damage it’s causing them or anyone else). Some back-of-the-envelope calculations (jump to table) suggest that, below a certain threshold of both total bank size and per-depositor funds, some banks simply don’t have the resources to comply with FATCA — and so, unsurprisingly, only a small proportion of institutions in low-income countries have signed FFI agreements. In Malawi, for example, it looks like only a quarter of the banks with SWIFT codes are in the FFI list.
In fact, about a dozen countries still have no FFIs registered at all. Ironically, one of them is Eritrea, the U.S.’ sole fellow believer in the ideology of imposing universal, unending taxation on emigrants.
