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Even though the Nedbank Africa Region (NAR) subsidiaries have not signed an IGA with the US*, the subsidiaries are part of the Nedbank Group and therefore they become, what is called, "participating foreign financial institutions* (participating FFIs)".
This means that for Nedbank Group as a whole to remain compliant with FATCA, the NAR subsidiaries must provide all the relevant data required to comply with this legislation because they form part of the "expanded affiliated group"* called Nedbank Group.
*For any defined terms please see the Table of terms and definitions.