Policy Points Series

The STEP Policy Points have been created to inform members of relevant policy issues and the action STEP is taking on them.

Each document contains a brief background on the issue itself, details about how STEP has responded and information about other key stakeholders.

To ensure accuracy the series is checked and updated regularly, in line with any pertinent developments.

At present the Policy Points Series consists of:

  • The Fifth Anti-Money Laundering Directive
  • DAC6
  • The Financial Action Task Force
  • OECD Mandatory Disclosure Rules

If you know of an issue which you think may benefit from having its own Policy Point please let STEP know via the following address: policy@step.org

Fifth Anti-Money Laundering Directive

The legislation updates the EU’s approach to anti-money laundering. It is currently in the implementation phase in Member States, with the deadline for this process being scheduled for 2020.

Although the Directive covers a wide range of issues, such as the use of cryptocurrencies, the status of Politically Exposed Persons (PEPs) and enhanced rules for dealing with countries deemed to be ‘high risk’ there are a number of provisions which will impact the work of STEP members.

To read more about the relevant parts of the legislation please access our Policy Point (PDF (292KB)


EU Legislation on Reportable Cross Border Arrangements

Following the BEPs Action 12 Report the EU amended its Directive on Administrative Cooperation in the Field of Taxation (DAC).

The new rules focus on the role of intermediaries in designing or promoting tax planning schemes that are deemed aggressive. The legislation will require those involved in these activities to make reports to the relevant national governments. Any reports made will be automatically exchanged between Member States.

The date for Member States to transpose the legislation into their own legal systems has been set for December 2019, with the first automatic exchanges planned for mid-2020.

To find out more about this issue please access our Policy Point (PDF 249KB)

The Financial Action Task Force

The Financial Action Task Force

STEP engages with the Financial Action Task Force on a number of issues.

This Policy Point outlines the work STEP has done on the following two topics:

  1. The UK’s first evaluation under the FATF’s mutual evaluation system.
  2. The production of FATF’s risk based approach (RBA) for professional intermediaries.

To find out more about these issues and STEP’s work on them please access our Policy Point (PDF 261KB)

OECD Mandatory Disclosure Rules

Title: The OECD Mandatory Disclosure Rules

Text: The OECD issued new model disclosure rules in 2018.

The rules require intermediaries to inform tax authorities of any schemes they put in place for their clients to avoid reporting under the OECD/G20 Common Reporting Standard (CRS) or prevent the identification of the beneficial owners of entities or trusts.

To find out more about the rules and STEP’s work in response to them please access our Policy Point (PDF 264KB)