'FATCA — represented by both individual FI agreements and the model IGA —
should be recognised for what it truly is; a trade barrier that is being unilaterally imposed by one
trading partner (USA) on another (Australia). As with all trade barriers, the choice is to meet the
additional costs imposed or lose access to the market. The compliance burden is a cost that will
initially be met by FIs, but will simply be passed on to individual consumers as banking fees or as
reduced investment returns. This is the equivalent of a direct trade tariff, except that the benefits
accruing to the tariff-imposing country are widely recognised as far less than the burden being
imposed on the target country....'
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