For years, tax has been AML’s dirty little secret. Many’s the time an MLRO has taken me to one side just before a training session and asked, “Could you just mention, you know, just in passing, *whisper* tax to them – remind them to ask questions, but not to pry…”. And I’ve lost count of how often I have been asked – and not by junior staff, I hasten to add – whether tax evasion “counts” for money laundering. Apparently there are three main categories of activity in life: crime, non-crime, and tax matters.
But it seems that public opinion might be shifting – and where the public leads, our customers will follow, what with being part of that public. The HSBC fiasco has helped, of course: tales of the mega-rich squirrelling away their proceeds of tax evasion will always upset people. But it’s not just evasion now – it’s avoidance too that’s getting the cold shoulder. Last week a friend of a friend contacted me to say that she wanted to buy my two novels, but not from Amazon as she is boycotting them for not paying their tax as she feels they should. (I gave her links to other places – I never let a potential reader escape.) And then this story appeared on the BBC website, about rich people who are happy to pay their taxes – among them, author JK Rowling, comedians Frank Skinner and Ricky Gervais and retailer Mark Constantine (who set up niffy cosmetics chain Lush). They state variously that paying tax is a moral issue, that taking action to avoid tax is contemptible, and that tax exiles are unsavoury.
So are we reaching the point where asking customers about their tax situation will no longer be considered prying or prurient, but rather the mark of a socially-responsible organisation? Might we see one day, on client take-on forms, a requirement for applications to sign the declaration “I confirm that I have met my tax liabilities in full, in all applicable jurisdictions”? In short, in the same way as businesses now proudly flaunt their green credentials, with energy-efficient window blinds and cycle parking for staff, might they soon start to boast of their pro-tax stance?