privilege "in cases in which the attorney is acting as a financial intermediary or in some other strictly fiduciary or transactional capacity, rather than as a legal advocate".66 Secondly, international cooperation is essential to the success of the provisions concerning the need to identify the beneficial owner: in order to save the considerable costs involved in having to seek information concerning the "real owners" of companies from authorities of another country than the country where the company is registered, countries should be encouraged to adopt regulations to ensure that information concerning beneficial ownership of any entity incorporated under its laws is available with a person who is resident in that country.67 In order for the AML/CFT standards to be truly effective, the incentives of bankers should be aligned with the legal duties imposed on the financial institutions themselves. This is not currently the case. Global Witness rightly notes that, as long as prosecuting authorities will remain hesitant to impose sanctions on the bank executives themselves, as individuals, these executives will remain tempted to treat the risk of their institution being fined for lack of due diligence in dealing with funds of suspect origin as a mere "business risk", that may be worth taking as long as the benefits outweigh the potential costs to the institution. It is encouraging to note, however, that in recent years prosecuting authorities (particularly in the United States) have appeared more willing to impose sanctions not only on financial institutions, but also on individuals working within such institutions -- although more frequently on middle-level employees than on the "directing minds" such as CEOs and members of the board --.68 5. Participation and accountability in taxation policies After the Committee on Economic, Social and Cultural Rights expressed its concern about fiscal reforms introduced by the United Kingdom, such as increases in the threshold for the payment of inheritance tax and increases of the value added tax or cuts to the tax rates of corporations, it recommended that the UK "conduct a human rights impact assessment, with broad public participation, of the recent changes introduced to its fiscal policy, including an analysis of the distributional consequences and the tax burden of different income sectors and marginalized and disadvantaged groups".69 Similarly, the Special Procedures of the Human Rights Council that deplored the impacts on poor families of the Welfare Reform and Work Act enacted by the UK in 2016, criticized the lack of credibility of the impact assessments preceding the cuts to welfare benefits, noting that these cuts were based on often unproven assumptions and that the government had failed to explore the full range of alternative options to ensure the sustainability of the welfare system ; and they asked the government to indicate whether they had 66 Id., at 6. The 2015 EU Anti-Money Laundering and Terrorist Financing Directive provides in this regard that, whereas "obliged entities" "know, suspect or have reasonable grounds to suspect" that funds result from criminal activity or are related to terrorist financing should report their suspicion to the authorities, this may not apply to "notaries, other independent legal professionals, auditors, external accountants and tax advisors only to the strict extent that such exemption relates to information that they receive from, or obtain on, one of their clients, in the course of ascertaining the legal position of their client, or performing their task of defending or representing that client in, or concerning, judicial proceedings, including providing advice on instituting or avoiding such proceedings, whether such information is received or obtained before, during or after such proceedings" (emphasis added): see Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC, OJ L 141, 5.6.2015, p. 73–117. 67 E. van der Does de Willebois, et al., The Puppet Masters, cited above note 64, at 7. This is why the 2015 EU Anti-Money Laundering and Terrorist Financing Directive provides that the EU Member States must ensure that "corporate and other legal entities incorporated within their territory are required to obtain and hold adequate, accurate and current information on their beneficial ownership, including the details of the beneficial interests held": see Art. 20(1) of the EU Anti-Money Laundering and Terrorist Financing Directive, cited above, note 63. 68 For details, see Global Witness, Banks and Dirty Money. How the financial system enables state looting at a devastating human cost (2015). The recent EU Anti-Money Laundering and Terrorist Financing Directive again represents a promising step in this direction: it provides that where legal persons are found to have breached their obligations under the national law implementing the directive, "sanctions and measures can be applied to the members of the management body and to other natural persons who under national law are responsible for the breach": see Art. 58(4) of the EU Anti-Money Laundering and Terrorist Financing Directive, cited above, note 66. 69 Committee on Economic, Social and Cultural Rights, Concluding Observations on the sixth periodic report of the United Kingdom of Great Britain and Northern Ireland (UN doc. E/C.12/GBR/CO/6, 14 July 2016), para. 17. 18 CRIDHO Working Paper 2017/1