4.1 defensive or offensive reporting by reporting entities? 51
4.2 weakening of the existing AML/CFT-regime resource-wise (private sector and public sector)
52
4.3 The fruit of the poisonous tree: the use of stolen data in criminal and tax procedures 53
4.4 Will voluntary disclosures still be possible and made if tax crimes have become predicate
offences to ML? 53
4.5 Will the FIUs become the long arm of the tax administration? Or have they already in
certain countries? 54
5. Conclusions 56
Reference list 58
List of abbreviations 61
Annexes 64
ANNEX A 64
ANNEX B 67
ANNEX C 69
Austrian Financial Crime Act 69
$ 261 German Criminal Code 72
$ 31b German Fiscal Code 76
$ 370 German Fiscal Code 78
Art. 506-1 Criminal Code of Luxembourg 80
ANNEX D 82
Table of potential sentences related to tax crimes as predicate offences to ML in Austria 82
ANNEX E 85
The inverted reporting cascade 85
Affidavit 86