Foreign Financial Institution (FFI)

A Foreign Financial Institution is a non-United States bank, custodian or investment entity subject to FATCA reporting on accounts held by United States persons.
Foreign Financial Institution (FFI) – definition card from the Heavnn University tax and residency glossary

What Is a Foreign Financial Institution (FFI)?

A Foreign Financial Institution is a non-United States bank, custodian or investment entity subject to FATCA reporting on accounts held by United States persons.

Also known as: FFI, FATCA Financial Institution.

How Foreign Financial Institution (FFI) works

A Foreign Financial Institution is any financial institution organised outside the United States, such as a bank accepting deposits, a custodian holding assets for others or an entity primarily investing or trading in securities, which United States law brings within FATCA reporting and withholding rules under 26 U.S.C. 1471. Registered FFIs agree to identify and report United States accounts and receive a Global Intermediary Identification Number, while non-participating FFIs face a 30 percent withholding tax on certain United States-source payments. Where Country A has signed an intergovernmental agreement, local law and the local tax authority usually govern the detail, so obligations vary by jurisdiction.

Foreign Financial Institution (FFI) vs Active NFE

Unlike an Active NFE or other non-financial foreign entity, which is classified on the basis of an operating business, a Foreign Financial Institution is classified by financial activities such as deposit-taking, custody or investing for others.

Example

Illustrative example: A dual national holding United States citizenship opens a current account with a bank in Country A. The bank, as a Foreign Financial Institution, generally asks for a self-certification, records the United States indicia and reports the account to the Country A tax authority or the IRS under the applicable FATCA framework.

Common misconception

Myth: Only large Swiss or offshore banks count as foreign financial institutions.

Reality: A Foreign Financial Institution can include ordinary retail banks, brokers, custodians, insurers with cash-value products and investment funds in any country outside the United States.

Frequently asked questions

What is a foreign financial institution under FATCA?

A Foreign Financial Institution under FATCA is a non-United States entity which accepts deposits, holds financial assets for others as a substantial business, or primarily invests or trades in securities, partnership interests or commodities.

Why does a foreign bank ask about US citizenship?

A Foreign Financial Institution generally asks about United States citizenship or residence to identify reportable accounts under FATCA, either under an intergovernmental agreement or an FFI agreement with the IRS.

Sources

Last verified: 2026-10-08. This entry is general information, not tax or legal advice; rules vary by country and change over time.

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