Last week, the European Banking Authority (EBA) issued an action plan to enhance the regulatory and anti-money laundering (AML) supervision of banks/firms engaged in transactions that may incorporate tax evasion or the laundering of the proceeds of tax evasion.
The plan arose out of a recent regulatory supervision review and controls that failed or facilitated a dividend arbitrage scheme, known as “cum-ex.” The scheme has also been the subject of a criminal prosecution in Germany, which saw two ex-British bankers found guilty of tax fraud. On March 18, right around the time many of us went into lockdown, the two ex-bankers avoided imprisonment because they cooperated and provided assistance to the authorities.
