Victoria has an excellent post on her blog today: FATCA: A Project Audit.
She gives great insight into what might be said about FATCA in an audit. Here are key points she thinks would be found.
Failure to identify the stakeholders.
Failure to do proper assessment of the impact and risks.
Lack of success criteria.
An out of control core model.
After her superb analysis, Victoria concludes:
Stepping back and looking at it very coldly, FATCA may represent one of the riskiest projects the U.S. has ever tried to push on the international stage.
Or, as Victoria describes in simpler terms:
FATCA is rapidly becoming a bowl of spaghetti the kids are trying to eat on a white couch.
I have no idea why Congress, IRS and US Treasury ever thought it was a good idea to have a white couch.