The input to this response has been curated through a series of member discussions, industry engagement, and roundtables, and GDF is grateful to its members who have taken part. The following are the key principles discussed in further detail in our full response to this consultation:
1.) Clarity of Definitions
2.) Timing of implementation – regulatory grace period encouraged
3.) Encouraged alignment and harmonisation between the UK’s AEOI regimes and domestic reporting requirements
4.) Garbage in Garbage out – Challenges around completeness and accuracy of information
5.) Digital ID
6.) Transaction Volume in a Web 3 ecosystem