ACCA response to EU Anti-Money Laundering Directive

06 July 2016

ACCA supports the amendments brought to the fourth anti-money laundering Directive as well as the related revision of the Directive on Administrative Cooperation in the field of taxation.

Chas Roy-Chowdhury, head of Taxation at ACCA says: [...] 'In particular, we are pleased to see proposals to widen the scope of the information accessible to Financial Intelligence Units, whose role is crucial, as well as their steady cooperation. We also share the Commission’s view that, in our digitalised era, it is necessary and urgent to introduce due diligence requirements for the exchange of virtual currencies, such as bit coin, and to strengthen the verifications and controls on pre-paid instruments such as prepaid cards. These are important in tackling black market and terrorist financing.'

ACCA also commends the move towards more transparency and better access to beneficial ownership information, in line with the G20’s call to the OECD and FATF (Financial Action Task Force) for a new global transparency standard for beneficial ownership. 

Chas Roy-Chowdhury explains: 'We also command the work undertaken by the Commission in examining the most appropriate framework for the implementation of the automatic exchange of information on beneficial ownership at EU level.  The proposal to integrate it into the binding tax transparency framework already in place in the EU could indeed make sense. It’s vital to stop global gaps in exchange of information, and we would recommend imposing fines on member states which do not meet requirements for timely and accurate information exchange.'

ACCA also welcomes the forthcoming public consultation on how to increase oversight and put in place effective disincentives for promoters and enablers of aggressive tax planning schemes. It is in line with OECD's BEPS Action 12 recommendations that countries should require tax payers and professions like tax and legal advisors, or financial intermediaries, to disclose any aggressive tax planning schemes that they use or promote. 

ACCA is also in favour of promoting higher tax good governance standards worldwide, agreeing with the principle of an EU list of non-cooperative jurisdictions, while urging the Commission to also work closely with the OECD for the development of an ambitious and effective international list.

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