The Foreign Account Tax Compliance Act ("FATCA") requires Foreign Financial Institutions ("FFIs") , among other duties, to register with the US Internal Revenue Service ("IRS") and obtain a Global Intermediary Identification Number ("GIIN").
Although FATCA is designed to ensure that US persons report their non-US financial assets to the IRS, all FFIs / funds, FATCA generally requires certain foreign (i.e., non-US) entities to conduct diligence and reporting regarding their investors.
Many countries have entered into intergovernmental agreements (“IGAs”) with the United States, which requires their registered FIs to comply with FATCA.
Even though your fund might not have any US investors, if it is domiciled in a country that has entered an IGA with the US, e.g. Cayman, BVI, Luxembourg, your fund will have to comply with FATCA, and therefore requires a GIIN.