Implementing a Data Sandbox to Ensure FATCA Regulatory Compliance

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Our client, a European-based multinational financial services holding company operating an investment bank, private bank, and an asset management group, needed a proactive data driven solution to identify and manage tax compliance for in-scope counter parties.  By creating a sandbox environment with production-like data, we helped our client identify and take action on open compliance issues ahead of regulatory deadlines.


US Foreign Account Tax Compliance Act (FATCA) and UK Common Reporting Standards (CRS) regulations required our client to be able to identify client accounts and counter parties that fall within scope of each Act and ensure proper tax documentation ink to avoid withholding penalties resulting from non-compliance.  In addition to the requirements of the regulations, management had mandated that the bank would not be conducting business with non-compliant entities and all accounts must be suspended until full compliance had been achieved.


The Sagence team worked with various stakeholders from client onboarding, taxation and global FATCA desk to understand scope requirements and translate into data requirements for clients facing US or UK Investment Bank entities.  By combining data from various systems within a homegrown sandbox environment the team was able to “front-run” a production environment solution, allowing client outreach teams to process clients without having to wait for an IT solution that would have been past compliance dates for earliest phase deadlines.


The client was able to meet compliance dates for earliest phases of regulations and obtain insight into sizing for later phase efforts.  The agile development used in producing the solution allowed for continual improvement while still producing actionable intelligence.  The requirements gathered and implemented by the team have been applied to production lifecycle development and are being applied to other regions outside of US/UK, such as APAC.