ance officers and client relationship managers by too large a multitude of different national implemen- 
tations or unequal risks attached to different markets, or over-motivating financial institutions to push 
their clients into waiving unnecessarily their legal rights? No, none if these issues seem to have been 
discussed within the FATF, the EU-platform of FIUs, Moneyval or another FSRB, or national task 
forces on AML/CFT, at least no report on these discussions was published so far. 
Summing up the above arguments in favour or against the inclusion of tax crimes as predicate offences 
to ML, there seem to be more against doing it, at least as long as the European Commission has not 
published its assessment mentioned in chapter 2.1.2.1 above. Countries having established a function- 
ing AEOI could consider limiting the scope of their statute on tax crime as predicate offence to ML to 
countries with which there is no AEOI in place. 
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