FATCA: A Project Audit

Victoria has an excellent post on her blog today:  FATCA: A Project Audit.
Victoria looks at FATCA through the lens of her professional experience computer auditmanaging large information systems for multi-nationals.
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.
Let’s be kids with spaghetti. Let’s spaghetti FATCA until it looks like this!Spaghetti Baby

5 thoughts on “FATCA: A Project Audit

  1. Thanks Abused. I also posted that under What’s New, but it’s great that it’s here too so more may see it.
    I also tweeted it to Carl Levin, US Treasury and others.
    It certainly captures it, doesn’t it? Of course, it was written by an American in Britain, so she knows about it from personal experience.

  2. Victoria is absolutely spot on in her analysis. I imagine she’s very successful in her IT project management career. Anyone who’s been in the situation she describes below can attest to the accuracy of her statement.
    “… feels a lot like some of the global projects I’ve worked on where company HQ decides unilaterally to impose a new system on its subsidiaries around the world. What appears straightforward, logical and necessary to the home office in Houston or Paris is often completely illogical and unworkable when it hits the ground in Tokyo or Sao Paulo.”
    Unfortunately, I believe that as far as governments are concerned, the way FATCA came about, with little thought and analysis, is the norm, not the exception.
    I hope someone influential in the US government reads her post, but I doubt it.

  3. @Outraged: That article was posted on a couple of other threads. It was originally published in Wall Street Journal. We have just learned the author is a former Deputy Secretary of State. That’s a pretty senior position at DOS, so it’s one more impressive ally on our side!
    Here’s the article which identifies her:
    It’s great to know it’s being published elsewhere. Plus, it was published under different titles in the American and European editions of WSJ, so it’s getting lots of traction.

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