A lot of countries have not signed an IGA but are treated as having one in place. The U.S. Treasury has previously set a deadline of December 31st for signing the IGAs. Now that deadline is approaching Treasury has announced an extension to this deadline. The status of a countries FFI as being treated as having an IGA in place where it not signed yet will be reviewed by the U.S. on a country by country basis.
Whilst this seems to be lenient in fact it makes the case for FFIs to keep tabs on their counterparties a lot harder.