The document discusses proposed changes to the Qualified Intermediary (QI) agreement and compliance issues organizations need to consider. It outlines new documentation requirements from the US Treasury and guidance on improving internal controls and audit processes to prevent tax evasion. The strategies suggested include clearly defining roles and responsibilities, maintaining accurate account records, and ensuring all transactions are properly archived.

1. • Proposed changes to the QI agreement • Satisfying documentation requirements • Compliance and operational issues for consideration

11. ? Amoranto Consulting 2009