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Certified System: FATCA/QI Compliance Policy

POLICY
Name : FATCA/QI Compliance Policy
Code : 60
Standard’s System Code :
Responsible Unit : Group Compliance & Regulatory Requests Division
Purpose : The “FATCA/QI Compliance Policy” describes the minimum
set of rules and procedures applicable to the U.S. Foreign
Account Tax Compliance Act –FATCA (chapter 4 of the U.S.
Internal Revenue Code) as well as the Qualified Intermediary
requirements –QI (chapter 3 of the U.S. Internal Revenue
Code), in relation to the Bank’s client classification, due
diligence, withholding and reporting obligations.
Applicable to : Eurobank Group
Version : 1.0
Valid as of : 07/08/2015
Distribution : Eurobank Group

Created by: Approved by: Issued by:

Unit: Unit: Unit:
Group Compliance Sector EXBO Group Organization & Planning
D. Manoussaki Sector
Date: 17/06/2015

Unit:
Group Compliance Sector

Head of Unit: Head of Unit: Head of Unit:

M. Skalistiri M. Skalistiri P. Maniati

Date: 08/06/2015 Date: 08/06/2015 Date: 07/08/2015

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TABLE OF CONTENTS

1. INTRODUCTION

2. OBJECTIVE

3. DESCRIPTION

4. TERMINOLOGY

5. ABBREVIATIONS

6. APPENDIX

7. REFERENCES

8. AMENDMENTS TABLE

9. TABLE OF CONTROLS and APPROVALS

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1. INTRODUCTION

1.1. Background
The U.S. Qualified Intermediary (QI) regime was introduced by the Internal Revenue Services (IRS) and
became effective as from 1 January 2001 (chapter 3 of the U.S. Tax Code). The two purposes of this
regulation were to identify U.S. persons investing in U.S. securities through foreign intermediaries and to
ensure a correct application of the double taxation treaties concluded by the United States, and more
generally, of the U.S. withholding tax to be applied to foreign persons.
In the interests of its clients and considering that the majority of the clientele of Eurobank Ergasias SA is
non-U.S., Eurobank Ergasias S.A. signed the Qualified Intermediary Agreement (QIA) with the U.S. tax
authorities and obtained the QI status in 2001.
Since the signature of the QIA, Eurobank Ergasias has been subject to a set of responsibilities including
the identification of customers, withholding and annual reporting as well as a specific procedure in
relation to U.S. clients whereby these clients are reminded on an annual basis of their respective tax
obligations towards the U.S. tax authorities.

1.2. The New FATCA Regulation

The Foreign Account Tax Compliance Act (FATCA) is an U.S. legislation (chapter 4 of the U.S. Tax
Code) enacted on 18 March 2010 as a response to combat tax evasion by U.S. taxpayers holding financial
accounts and other assets outside the U.S, increasing the ability of the IRS to detect U.S. tax evaders. The
primary objective of FATCA is reporting, both by U.S. taxpayers themselves about certain financial
accounts and offshore assets and by Foreign Financial Institutions (FFIs) about financial accounts held by
U.S. taxpayers or foreign entities in which U.S. taxpayers hold a substantial ownership interest. The
provisions of FATCA are founded on three pillars which include Due Diligence (including identification
and classification), Reporting and Withholding obligations. Its requirements and obligations started taking
effect from 01.07.2014 onwards.
In the context of FATCA, numerous countries around the world have signed Intergovernmental
Agreements (IGAs) with the U.S. We note that all countries where the Group currently operates have
either signed or have reached an agreement in substance for a Model 1 IGA1
Eurobank Ergasias S.A. Management and all its eligible Group entities which are members of its
expanded affiliated group (50% plus owned subsidiary companies) shall comply with the respective IGA
and relevant legislation of the country in which they operate.

1.3. Applicability
The principles of the present Policy in relation to FATCA, apply equally to all the foreign banking
subsidiaries and branches of the Eurobank Group as well as all other subsidiaries that are considered as
financial institutions under the Act (including Asset Management Companies, Equity companies, Life
Insurance Companies, Credit Card issuers and/or servicers), modified where necessary to conform to the

1
Please refer to the Terminology section for the definition of IGA.

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local legislation in force and be in alignment with local regulations. All modifications must be approved
by the Eurobank Group Compliance Division. The principles of the present Policy in relation to QI apply
only to Eurobank Ergasias S.A. and to Eurobank Private Bank Luxembourg S.A. With regards to its
responsibilities as a QI, Eurobank Ergasias S.A. has assumed secondary withholding responsibility.

2. OBJECTIVE
The “FATCA/QI Compliance Policy” has as its primary goal to outline the minimum set of rules and
procedures applicable in relation to the U.S. Foreign Account Tax Compliance Act –FATCA as well as
the Qualified Intermediary requirements –QI, where applicable, in relation to the Bank’s client due
diligence, reporting and withholding obligations.
The present Policy is being modified by the Eurobank Group Compliance Division:

according to the legislation/regulations in force;

in cases where significant deficiencies are observed in the measures taken;

in cases where significant changes in the business activities of the Group impose additional or
different measures.

3. DESCRIPTION

3.1 KEY ELEMENTS OF FATCA

FATCA encompasses the following key elements:

 Registration with the IRS (see section 3.1.1.);
 Implementation of due diligence on account holders -including identification and classification (see
section 3.1.2.);
 Tax Reporting (see section 3.1.3.);
 Tax Withholding (see section 3.1.4.);
 Monitoring of FATCA compliance (see section 3.1.5.).

3.1.1. Registration with the IRS

Group Compliance is responsible for the identification of Group entities that are eligible for FATCA
Registration. Group Corporate Governance is responsible to provide to Group Compliance any changes in
relation to Group Subsidiary Companies regarding any change in the activities of an existing subsidiary,
as well as the addition or closure of an entity. Group Compliance is responsible for providing instructions
to the eligible entities of the Group in relation to their registration with the IRS for FATCA.
Each eligible Group entity appoints a Responsible Officer (RO) for FATCA compliance as well as a
number of Points of Contact (POCs) responsible for the registration of the entity on the IRS FATCA
portal. Branches do not need to register separately.

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A Financial Institution2 (FI) may register as a Single FI, Lead FI, Member FI or Sponsoring Entity.
Eurobank Ergasias S.A. has been registered by Group Compliance as Lead FI of the Group. Each eligible
entity in the Group carries out its own registration in accordance with the instructions received by Group
Compliance (submits the 8957 registration form to Group Compliance for review and when it receives
clearance proceeds with the registration on the IRS FATCA portal). Each Group entity must ensure that it
includes the Group Compliance Officer, who is the Responsible Officer for the Lead FI, as one of the five
allowed POCs when performing its own registration.
Group Compliance, in the context of registering Eurobank Ergasias S.A. as Lead FI, must initiate the
registration of each eligible Group entity and provide the entity with the respective registration codes so
that the entity can then proceed with its own registration. Group Compliance could perform the
registration of an entity, as it is given such ability through the IRS FATCA registration portal, however, it
is Group decision that each entity perform its own registration. In any case, through the portal, Group
Compliance has the ability to monitor the status of all the registered entities of the Group.
Group Entities shall register according to the provisions of the IGA signed by the country itself; in this
context all eligible Group entities have registered with FATCA Status: “Reporting Model 1 FFI”.

3.1.2. Implementation of due diligence on account holders

The foundation of FATCA lies in the ability to properly classify customers (including counterparties,
account holders, etc.) according to the proposed FATCA classification guidelines and report on U.S.
persons whether they own an account directly or indirectly through a foreign entity. This requires FIs to
collect the appropriate withholding certificates, statements and documentary evidence from their
customers, and validate and store the information and documentation received.
In accordance with FATCA, FIs are required to perform additional due diligence on account holders in
case there are U.S. Indicia identified, in order to establish whether or not the Account Holders are indeed
eligible for paying tax in the U.S. This additional due diligence shall be performed both during the
initiation of a business relationship/account opening as well as during a change of client circumstances. In
case such indicia are identified, a client shall be asked to submit the respective documents verifying the
client’s tax situation.
The indicia specified in the FATCA regulation are the following:
• U.S. citizenship or residence;
• U.S. place of birth (in case of natural persons);
• A current U.S. residence address or U.S. mailing address (including a U.S. post office box);
• A current U.S. telephone number;
• Standing instructions to pay amounts from the account to an account maintained in the United
States;
• A current power of attorney or signatory authority granted to a person with a U.S. address; or
• An “in-care-of” address or a “hold mail” address that is the sole address that the FI has identified
for the account holder.

2
Please refer to the Terminology section for the definition of FI.

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In relation to Legal Entities, the due diligence performed must reach the level of the true beneficial
owner(s) of the entity, to establish whether there are any Controlling Persons that are U.S. Persons or
Specified U.S. Persons.3
We note that Eurobank Ergasias S.A. does not accept standing instructions to pay amounts to an account
in the U.S. and does not offer “in-care-of” or “hold mail” services. In case Group Entities offer such
facilities, these must be included in the U.S. Indicia as per FATCA requirements.
New customer/account opening due diligence
Each eligible Group entity ensures that account opening procedures are amended to ensure that relevant
information and/or documents are obtained during the initiation of a new relationship or new account
opening. Specific instructions should be provided in relation to FIs, legal entities apart from FIs, as well
as individual clients.
We note that Eurobank Ergasias S.A. as well as all eligible Group entities have implemented respective
account opening procedures by 30.06.2014.
Pre-existing customer/account due diligence
All eligible entities must put in place processes and procedures to ensure that all relationships and/or
financial accounts that were initiated/opened up to and including 30.06.2014 are reviewed by the end of
2016 in accordance with the below.
• FIs: all pre-existing financial institutions (with the exception of prima facie FIs) shall be
contacted to submit the relevant self-certification form duly completed and signed within two
years from the Determination Date (as specified in the respective country’s IGA). Prima facie FIs
due diligence had to be performed prior to 01.07.2014; we note, however, that as there was no
such information kept in relation to counterparty FIs, no action was taken.
• Individual Customers: clients with aggregate account balances greater than or equal to USD 1
million equivalent (“High Value Accounts”) shall be subject to enhanced review (electronic
record search, paper file review, relationship officer enquiry) within one year from the
Determination Date (as specified in the respective country’s IGA), whereas customers with
aggregate account balances between USD 50 thousand and USD 1 million equivalent (“Lower
Value Accounts”) shall be subject to electronic review within two years from the Determination
Date (as specified in the respective country’s IGA). For clients with aggregate account balances
below USD 50 thousand equivalent there is no such due diligence obligation, however, they
could also be included in the review of the Lower Value Account category.
• Legal Entity Customers: legal entity clients with aggregate account balances above USD 250
thousand shall be subject to review within two years from the Determination Date (as specified in
the respective country’s IGA). For clients with aggregate account balances below USD 250
thousand equivalent there is no such due diligence obligation, however, they could also be
included in the review. In relation to Passive NFFEs (Passive Non Financial Foreign Entities),
information on the Controlling Persons (substantial beneficial owners) must also be reviewed.
On-going customer/account due diligence
All eligible entities must put in place processes and procedures to ensure on-going customer/account due
diligence, as described in the respective country IGA. More specifically:

3
Please refer to the Terminology section for the definition of Controlling Person, U.S. Person and Specified U.S. Person.

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• FIs: care must be taken to ensure that the W-8 self-certification forms on file are valid (not
expired). Moreover, compliant financial institutions can be also monitored through the list that is
published by the IRS on a monthly basis.
• Individual Customers: starting from 31.12.2015 and on an annual basis thereafter, accounts
exceeding the predefined thresholds shall be reviewed in accordance with the due diligence
requirements of the particular client category (as per aggregate account balance). Such review
must be completed by the end of June of the subsequent year.
• Legal Entity Customers: starting from 31.12.2015 and on an annual basis thereafter, legal entity
clients with aggregate account balances exceeding the predefined thresholds shall be subject to
review. Such review must be completed by the end of June of the subsequent year.
If there is a change of circumstances with respect to any customer/account, an appropriate review must be
performed and/or additional documentation obtained.

3.1.3. Tax Reporting

In accordance with FATCA requirements, the U.S. IRS must be provided with information in relation to
U.S. Persons or Specified U.S. Persons that are clients of the various eligible financial institutions as well
as with information on any amounts paid to non-compliant (recalcitrant) customers or Nonparticipating
FIs (NPFFIs).
In countries that have signed a Model 1 IGA, FIs shall provide all the required information with respect to
all Reportable Accounts (including recalcitrant accounts) as specified in the respective country’s IGA.
The reporting shall be performed electronically to the designated local authority specified in the IGA.
All eligible Group entities must put in place processes and procedures to ensure that such reporting will
commence on the given deadline. For Model 1 IGA countries the deadline for the first annual reporting
date is the 30 September 2015 (to the designated local authority). More specifically:
• For year 2014: the information that shall be reported in relation to each U.S. Person or Specified
U.S. Person identified during the period from 01.07.2014 to 31.12.2014 (i.e. from new account
openings during this period, High Value Account due diligence, etc.), shall include:
(a) Name;
(b) Address;
(c) U.S. Taxpayer Identification number (TIN), if applicable, of each Specified
U.S. Person that is an Account Holder of such account or, in case the Account
Holder is a passive NFFE, of the Controlling Persons that have been identified
as Specified U.S. Persons;
(d) Account number (or functional equivalent in the absence of an account
number);
(e) Name and identifying number (GIIN – Global Institution Identification
Number) of the Reporting FI;
(f) Account balance or value as at 31.12.2014 or, if the account under review was
closed after the 1.07.2014, immediately before closure.
• For year 2015: the reporting, for all the U.S. Persons or Specified U.S. Persons identified by
31.12.2015, shall include all of the above information plus total gross income paid or credited

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(incl. interest, dividends and other income generated from the assets held in the account, with the
exception of certain gross proceeds from the sale or redemption of property).
• For year 2016: the reporting, for all the U.S. Persons or Specified U.S. Persons identified by
31.12.2016, shall include all of the above information plus gross proceeds from the sale or
redemption of property paid or credited to custodial accounts.
• For every subsequent year: the reporting, for all U.S. Persons or Specified U.S. Persons
identified by the end of the year, shall include all of the above information.
In addition, for each of 2015 and 2016, each eligible Group entity shall report annually the name of each
Nonparticipating Financial Institution to which it has made payments and the aggregate amount of such
payments.

3.1.4. Tax Withholding

The withholding obligation applies to Participating FIs and to FIs from Model 2 IGA jurisdictions.
Model 1 FIs do not have an obligation to withhold on payments made to their clients; however, they must
withhold on U.S. source FDAP income paid to Nonparticipating FIs.
Eurobank Ergasias S.A. shall follow secondary withholding responsibility (the same practice it has
implemented for QI purposes). This means that the foreign custodian of the U.S. FDAP income payment
(i.e. from a U.S. investment, not just because a payment is in USD) will perform the required withholding
and the obligation of Eurobank will be to provide the required information/documentation to the
custodian in order to perform the withholding where required.
The withholding percentage specified in the FATCA regulation is 30%.
FFIs who do not wish to comply with the FATCA requirements (Nonparticipating FFIs) shall face a
withholding tax of 30% on income from U.S. assets held either in their own portfolio or in a custodial
capacity, while under certain circumstances a withholding tax of 30% may also apply to income from
non-U.S. securities.
If there is no U.S. FDAP income involved, there will be no withholding requirements.
Each eligible Group entity must ensure that it sets up adequate processes and procedures in relation to
FATCA withholding requirements within the set deadlines.
Withholding on Payments to Nonparticipating FIs
Starting from 01.07.2014, withholding shall apply only to prima facie FIs. In all other cases, withholding
shall commence on payments made on or after the date that is two years after the Determination Date (as
specified in the respective country’s IGA).

3.1.5. Monitoring of compliance with FATCA

The Group Entity’s Responsible Officer (RO) shall ensure that effective controls are put in place in
relation to FATCA compliance.

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3.2. PROHIBITION IN RELATION TO U.S. CUSTOMERS

3.2.1. Prohibition for U.S. Customers from Dealing in U.S. Securities

The Group has also decided not to execute transactions in U.S. securities for any of its U.S.
customers.
In this context, none of the Bank’s subsidiaries should allow any of its U.S. clients to deal in U.S.
Securities. Furthermore, non-U.S. clients investing in U.S. securities should have a signed and valid W-8
form on file (a sample of such forms can be found on the IRS website).
In this respect, each Banking entity should ensure alignment of the related internal processes.

3.2.2. Additional Prohibition

The Group has decided not to execute transactions in U.S. securities for any non-consenting client, a
client that has not signed a W-8 form, or a Nonparticipating FI.

4. TERMINOLOGY

Term Definition
Account Holder The term Account Holder means the person listed or identified
as the holder or beneficial owner of a Financial Account by the
Financial Institution that maintains the account.

Classification In relation to individuals means U.S. Person or non-U.S. Person

and for entities refers to the FATCA Status of the entity as per
W-8BEN-E form.

Controlling Persons
The term Controlling Persons (as included in the Model 1
Intergovernmental Agreements) means the natural persons who
exercise control over an Entity (substantial beneficial owners).
In the case of a trust, such terms means the settlor, the trustees,
the protector (if any), the beneficiaries or class of beneficiaries,
and any other natural person exercising ultimate effective
control over the trust and in the case of a legal arrangement other
than a trust, such terms means persons in equivalent or similar
positions. The term Controlling Persons shall be interpreted in a
manner consistent with the Financial Action Task Force
Recommendations.

Determination Date
The Determination Date means the date, on which the U.S.
Treasury Department determines not to apply withholding under
section 1471 of the U.S. Internal Revenue Code to the Financial
Institution of a country that has an intergovernmental agreement
with the U.S. in place. That date is:

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(a) 30 June 2014, in case of (i) a jurisdiction that signed

an agreement with the U.S. to implement FATCA or
facilitate FATCA implementation on or before 30
June 2014, or (ii) a jurisdiction that the U.S. Treasury
Department determined reached such an agreement in
substance on or before 30 June 2014, and is included
in the U.S. Treasury list of such jurisdictions; or
(b) 30 November 2014, in the case of a jurisdiction that
the U.S. Treasury Department determined reached
such an agreement in substance on or after 1 July
2014 and on or before 30 November 2014, and is
included in the U.S. Treasury list of such
jurisdictions; or
(c) the date of signature of such an intergovernmental
agreement, in the case of any other jurisdiction.

Financial Account The term Financial Account means, in general, any:

(i) Depository Account;
(ii) Custodial Account;
(iii) Equity or Debt Interest;
(iv) Cash Value Insurance or Annuity Contract.

Financial Institution (FI)
The term Financial Institution means a Custodial Institution, a
Depository Institution, an Investment Entity, or a Specified
Insurance Company. For registration purposes we distinguish
four types of FIs as defined below:
• Single FI: A Single FI is an FI that does not have
any Member FIs and is registering for itself or one
or more of its branches;
• Lead FI: A Lead FI is an FI that does have
Members in its Expanded Affiliated Group (EAG);
the Lead FI shall initiate the FATCA Registration
process for itself and each of its Member FIs
(Branches of an FI in countries outside the Lead FIs
country of residence, shall also be registered by the
Lead FI, but they will not have separate registration
accounts despite the fact that they shall be assigned
a separate GIIN). An EAG may alternatively
organize itself into subgroups, so long as all entities
with a registration requirement are registered. An FI
that acts as a Compliance FI for any members of the
EAG is, however, required to register each such
member as would a Lead FI for such members;
• Member FI: A Member FI is an FI that is
registering as a Member FI of an EAG that is not
acting as a Lead FI;
• Sponsoring Entity: A Sponsoring Entity is an
entity that will perform the due diligence,
withholding and reporting obligations of one or
more sponsored investment entities or controlled

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foreign corporations (Sponsored FIs).

FDAP Income The term FDAP means Fixed, Determinable, Annual, or

Periodic income.

Intergovernmental Agreement The term means the agreement between the Government of the
(IGA) U.S. and the Government of the foreign country to improve
international tax compliance and to implement FATCA. To that
end the IRS released two forms of IGA’s, referred to as Model 1
IGA and Model 2 IGA.

Under the Model 1 IGA the benefits are i) a simpler due

diligence requirements and ii) the FFIs report information on
U.S. account holders directly to their national tax authorities
who in turn will report to the IRS (automatic exchange of the
reported information with the IRS).

The Model 2 IGA requires FFIs to enter into an FFI agreement

and must report directly to the IRS.

The IRS publishes a list identifying all countries that are treated
as having in effect a Model 1 or a Model 2 IGA.

Internal Revenue Service The IRS is U.S.’s tax collection agency which administers the
(IRS) Internal Revenue Code enacted by Congress. It is a bureau of the
Department of the U.S. Treasury and provides America’s
taxpayers with the information necessary for them to understand
and meet their tax responsibilities.

NFFE The term NFFE means any Non-U.S. Entity that is not a
Financial Institution.

Nonparticipating FFIs An FFI other than a participating FFI, a deemed-compliant FFI,

(NPFFIs) or an exempt beneficial owner.

Passive Income The term passive income means the portion of gross income that
[FATCA Regulation § 1.1472- consists of:
1(c)(1)(iv)(A)] (1) Dividends, including substitute dividend amounts;
(2) Interest;
(3) Income equivalent to interest, including substitute
interest and amounts received from or with respect to
a pool of insurance contracts if the amounts received
depend in whole or part upon the performance of the
pool;
(4) Rents and royalties, other than rent and royalties
derived in the active conduct of a trade or business
conducted, at least in part, by employees of the NFFE;
(5) Annuities;
(6) The excess of gains over losses from the sale or
exchange of property that gives rise to passive income

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described in (1) to (5) of this section;

(7) The excess of gains over losses from transactions
(including futures, forwards, and similar transactions)
in any commodities, but not including:
(i) Any commodity hedging transaction,
determined by treating the entity as a
controlled foreign corporation, or
(ii) Active business gains or losses from the sale
of commodities, but only if substantially all
the foreign entity’s commodities are property;
(8) The excess of foreign currency gains over foreign
currency losses;
(9) Net income from notional principal contracts;
(10) Amounts received under cash value insurance
contracts;
(11) Amounts earned by an insurance company in
connection with its reserves for insurance and annuity
contracts.

Passive NFFE Any NFFE that is not an Active NFFE; in general, a passive
NFFE is an NFFE whose gross income is more that 50% Passive
Income.

Reporting Model 1 FFI An FFI with respect to which a foreign government or agency
thereof agrees to obtain and exchange information pursuant to a
Model 1 IGA, other than an FFI that is treated as a
Nonparticipating FFI under Model 1 IGA.

Qualified Intermediary (QI) • A qualified intermediary is any foreign intermediary (or

foreign branch of a U.S. intermediary), such as a bank,
broker or asset manager, that has entered into a qualified
intermediary withholding agreement with the IRS.
• A QI takes over certain U.S. tax law obligations and is
held responsible for the correct application of U.S. tax
rules with respect to payments of U.S. source income
made to its customers investing in U.S. securities
(including the correct application of double taxation
treaties applicable to foreign persons). In special
situations, this obligation may also apply for payments
of foreign source income made to U.S. customers.
• A QI may assume primary or secondary withholding
responsibility; primary responsibility meaning that the
QI is required to withhold the appropriate amount of
U.S. tax from the gross amount received by the
custodian and to regularly deposit the amounts withheld
with the IRS and secondary meaning that the QI
communicates adequate information to its withholding
agent which will withhold the correct amount and remit
only a net amount to the QI.
• A QI has a privileged status and is allowed not to

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disclose beneficial owner documentation with respect to

non-U.S. clients. Nevertheless, the QI status does not
avoid the disclosure to the IRS of all U.S. clients
investing in U.S. securities and thus receiving U.S.
source income.

Specified U.S. Person
The term Specified United States Person means any U.S. person
other than:
(i) a corporation the stock of which is regularly traded on
an established securities markets;
(ii) any corporation that is a member of the same
expanded affiliated group as a corporation the stock of
which is regularly traded on an established securities
market (described in (i) above);
(iii) the United States or any wholly owned agency or
instrumentality thereof;
(iv) any State of the United States, any U.S. territory, any
political subdivision of any of the foregoing, or any
wholly owned agency or instrumentality of any one or
more of the foregoing;
(v) any organization exempt from taxation under section
501(a) of the U.S. Internal Revenue Code or an individual
retirement plan as defined in section 7701(a)(37) of the
U.S. Internal Revenue Code;

(vi) any bank as defined in section 581 of the U.S. Internal

Revenue Code;
(vii) any real estate investment trust as defined in section
856 of the U.S. Internal Revenue Code;
(viii) any regulated investment company as defined in
section 581 of the U.S. Internal Revenue Code or any
entity registered with the U.S. Securities and Exchange
Commission under the Investment Company Act of 1940;
(ix) any common trust fund as defined in section 584(a) of
the U.S. Internal Revenue Code;
(x) any trust that is exempt from tax under section 664(c)
of the U.S. Internal Revenue Code or that is described in
section 4947(a)(1) of the U.S. Internal Revenue Code;

(xi) a dealer in securities, commodities, or derivative

financial instruments (including notional principal
contracts, futures, forwards, and options) that is registered
as such under the laws of the United States or any State;
(xii) a broker as defined in section 6045(c) of the U.S.
Internal Revenue Code; or
(xiii) any tax-exempt trust under a plan that is described in
section 403(b) or section 457(g) of the U.S. Internal
Revenue Code.

U.S. Indicia (a) Identification of the Account Holder as a U.S. citizen

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or resident;
(b) Unambiguous indication of a U.S. place of birth;
(c) Current U.S. mailing or residence address (including a
U.S. post office box);
(d) Current U.S. telephone number;
(e) Standing instructions to transfer funds to an account
maintained in the United States;
(f) Currently effective power of attorney or signatory
authority granted to a person with a U.S. address; or
(g) An “in-care-of” or “hold mail” address that is the sole
address that the Financial Institution has on file for the
Account Holder. In case of a Pre-existing Individual
Account that is a Lower Value Account, an “in-care-of”
address outside the United States or “hold mail” address
shall not be treated as U.S. indicia.

U.S. Person The term U.S. Person means

(a) a U.S. citizen or resident individual;
(b) a partnership or corporation organized in the
United States or under the laws of the United States or
any State thereof;
(c) a trust if (i) a court within the United States would
have authority under applicable law to render orders or
judgments concerning substantially all issues regarding
administration of the trust, and (ii) one or more U.S.
persons have the authority to control all substantial
decisions of the trust;
(d) an estate of a decedent that is a citizen or resident
of the United States.
This definition shall be interpreted in accordance with the U.S.
Internal Revenue Code.

U.S. Reportable Account The term means a Financial Account held by one or more
Specified U.S. Persons or by a Non-U.S. Entity with one or more
Controlling Persons that is a Specified U.S. Person.

U.S. TIN The term U.S. TIN means a U.S. federal taxpayer identification
number.

W-8 Certificate of foreign status with regards to U.S. withholding tax,

to be filled in by Non-U.S. Clients;
• W-8BEN: Certificate of Foreign Status of Beneficial
Owner for United States Tax Reporting and
Withholding for Individuals;
• W-8BEN-E: Certificate of Foreign Status of Beneficial
Owner for United States Tax Reporting and
Withholding for Legal Entities;
• W-8EXP: Certificate of Foreign Government or Other
Foreign Organization for United States Tax
Withholding (Note: For use by foreign governments,

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international organizations, foreign central banks of

issue, foreign tax-exempt organizations, foreign
foundations, and governments of U.S. possessions);
• W-8ECI: Certificate of Foreign Person’s Claim for
Exemption from Withholding on Income Effectively
Connected with the Conduct of a Trade or Business in
the United States (Note: Persons submitting this form
must file an annual U.S. income tax return to report
income claimed to be effectively connected with U.S.
trade or business).
• W-8IMY: Certificate of Foreign Intermediary, Foreign
Flow-Through Entity, or Certain U.S. Branches for
United States Tax Withholding and Reporting.

W-9 Certificate of U.S. status.

5. ABBREVIATIONS
FATCA –Foreign Account Tax Compliance Act
FFI –Foreign Financial Institution
FI –Financial Institution
GIIN –Global Intermediary Identification Number
IGA – Intergovernmental Agreement
IRS –Internal Revenue Service
NFFE –Non-Financial Foreign Entity
NPFFI –Non-Participating Financial Institution
PFFI –Participating Foreign Financial Institution
POCs –Points of Contact
RO –Responsible Officer
QI –Qualified Intermediary
QIA– Qualified Intermediary Agreement
TIN –Tax Identification Number

6. APPENDICES

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7. REFERENCES
• IRS website
• W-8BEN form
• W-8BEN-E form
• W-8EXP form
• W-8ECI form
• W-8IMY form
• W-9 form

8. AMENDMENTS TABLE

Version Date Change Description

1.0 07.08.2015 First Version

9. TABLE OF CONTROLS and APPROVALS

Organizational Unit Name / Signature of Date

Authorized Personnel
Policy Owner Group Compliance Sector M. Skalistiri 08/06/2015

Unit Involved

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