money laundered each year was the equivalent of 2-5% of total GDP, or 800 billion to 2 trillion USD.61 Some attempts have been made to make private financial actors aware of their responsibilities. The Financial Action Task Force (FATF), an independent intergovernmental body established in 1989 to support the fight against money laundering, adopted a set of recommendations addressed to its Member States. Known as the International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation (AML/CFT standards) the recommendations were initially drawn up in 1990; they were most recently updated in 2012, and have been endorsed by 180 countries.62 While it is not possible here to describe in detail the full set of recommendations, it may be relevant to note that they include imposing on financial institutions that they undertake customer due diligence (CDD) upon establishing business relationships with new clients or for occasional transactions, whether because they reach a certain level or because there is a suspicion of money laundering or terrorist financing. CDD means identifying the customer and verifying that customer’s identity ; identifying the "beneficial owner", and "taking reasonable measures to verify the identity of the beneficial owner, such that the financial institution is satisfied that it knows who the beneficial owner is": where the client is a corporation, this means understanding the corporate structure to see who is "behind" the corporate structure; "understanding and, ..., obtaining information on the purpose and intended nature of the business relationship"; "conducting ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the institution’s knowledge of the customer, their business and risk profile, including, where necessary, the source of funds".63 The FATF recommendations on the need to seek information about beneficial owners are of particular importance. Indeed, a major obstacle to the effective enforcement of money laundering regulations is that the identity of the real owners of corporate structures may remain hidden, or can only be known to the authorities in country A (where the company is domiciled and regulated) by seeking information from country B (from where the company is administered). Noting that in many cases financial institutions did not seek to identify the beneficial owner when establishing a business relationship, the authors of a World Bank 2011 study on the laundering of the products of economic crime highlight the importance of imposing due diligence obligations on banks and other financial intermediaries such as trust and company service providers.64 This, the study noted, would oblige service providers to "collect information and conduct due diligence on matters about which they might prefer to remain ignorant": "If a service provider is obligated to gather full due diligence information, it becomes impossible for the intermediary to legitimately plead ignorance regarding the background of a client or the source of his or her funds".65 Moreover, the collection of such information by the financial intermediaries facilitates inquiries, providing investigators with an adequate source of information. Even apart from the fact that they are not, by any means, fully implementated in the participating countries, the AML/CFT standards remain insufficient to effectively combat the widespread practice of tax evasion. Gaps remain, for instance, in enforcing the duty of financial institutions to ensure that they identify the beneficial owner. First, where investigators seek to have access to information detained by an attorney, the attorney-client privilege is invoked to oppose this and shield information from scrutiny. Such a barrier should be lifted where circumstances allow for this: the 2011 World Bank study already referred to above notes that many jurisdictions have introduced exceptions to the legal professional 61 See https://www.unodc.org/unodc/en/money-laundering/globalization.html (last consulted on 28 Feb. 2016). See for the text of the recommendations: http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf (last consulted on 28 Feb. 2016). 63 Recommendation 10. 64 E. van der Does de Willebois, E. M. Halter, R.A. Harrison, Ji Won Park and J.C. Sharman, The Puppet Masters. How the Corrupt Use Legal Structures to Hide Stolen Assets and What to Do About It (Stolen Asset Recovery Initiative, The World Bank / UNODC, 2011), available at: https://star.worldbank.org/star/sites/star/files/puppetmastersv1.pdf (last consulted on 28 Nov. 2016). 65 E. van der Does de Willebois, et al., The Puppet Masters, cited above note 64, at 5. 62 17 CRIDHO Working Paper 2017/1