Since the passage of the Foreign Account Tax Compliance Act (FATCA) in 2010, rumors have been swirling around financial institutions regarding its implementation. There was talk about the US requiring all foreign financial institutions (FFIs) to disclose the names of its US account holders to the IRS; about how a FFI’s non-participation in the FATCA program would turn it into a pariah in the financial community because no financial institution in the world will want to do business with a non-FATCA compliant FFI.