The Interaction of the Duty to Make a Suspicious Activity Report under the Proceeds of Crime Act and the Obligation to Report under Hallmark D of DAC6 and the OECD Mandatory Disclosure Regime

This article exists because of a disagreement. The authors regularly work together in practice and in print. They both work in the field of international tax information exchange regimes and have opinions that sometimes diverge. They diverge particularly in relation to the subject matter of this article.