During the multi-year build-up to FATCA,1 the primary focus was on entity classification and registration, and less attention was paid to the compliance obligations of U.S. and non-U.S. entities affected by FATCA. Withholding and information reporting responsibilities under FATCA were generally known, but with the numerous deadline postponements and references to yet-to-be enacted local law, many affected entities took a wait-and-see approach to FATCA compliance.