During the 2008 presidential campaign, Barack Obama promised to "create an international tax haven watch list of countries that do not share information returns with the United States." Obama hasn't done this precisely, but a new law now being implemented does even more.

That law is the Foreign Account Tax Compliance Act, part of a larger bill passed by the then-Democratic controlled House and Senate and signed by Obama on March 18, 2010.

The broad purpose of the law, according to the the Government Accountability Office, is "to reduce tax evasion by creating greater transparency and accountability with respect to offshore accounts and entities held by U.S. taxpayers and by providing IRS with tools to further enforce tax laws. IRS believes that implementing these new requirements will increase tax compliance, which will help close the gap between taxes owed and taxes paid. IRS recently estimated a net tax gap of $385 billion for tax year 2006, though IRS has not estimated the percentage of the tax gap specifically attributable to offshore accounts."

Specifically, under the law, "certain U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS. In addition, FATCA will require foreign financial institutions to report directly to the IRS certain information about financial accounts held by U.S. taxpayers, or by foreign entities in which U.S. taxpayers hold a substantial ownership interest," according to the Internal Revenue Service.

This is more far-reaching than just creating a list -- it's a whole new layer of scrutiny for both Americans who have overseas accounts and foreign financial institutions that have Americans among their account-holders.

Indeed, this long reach has inspired a fierce backlash in some quarters, citing bureaucratic costs and privacy concerns, among other issues. Some European banks have reportedly said they won't serve U.S. investors once the law is fully implemented in 2013, citing the penalties they'd be subject to for a failure to comply.

"FATCA goes far beyond tax havens -- it applies to everyone," said H. David Rosenbloom, director of the International Tax Program at the New York University School of Law.

In Rosenbloom's view, "FATCA is an expensive, resource-wasting mess." But the Obameter doesn't assess whether the policies implemented are good, bad or somewhere in between -- only whether they fulfill a campaign promise. In this case, FATCA goes well beyond what Obama pledged during the campaign. So we rate it a Promise Kept.