With regard to the OECD publications, the EBA strongly supports and promotes that firms use publicly available information and knowhow, including publications by intergovernmental organizations. As OECD highlights on its website, there are substantial similarities between the techniques used to launder the proceeds of crimes and to commit tax crimes. It is key for supervisors and firms to enhance their understanding of tax crimes, which the EBA has also stressed in several products, more in particular the Report on competent authorities' approaches to tackling market integrity risks associated with dividend arbitrage schemes (EBA/REP/2020/15), the action plan on dividend arbitrage trading schemes [Action plan on dividend arbitrage trading schemes Cum-ExCum-Cum.pdf (europa.eu).] and the revised Internal Governance Guidelines (as per the recent Consultation Paper, EBA/CP/2020/20). At the same time, in the EBA's view, Guideline 1.30 and 1.31 include a sufficiently comprehensive list of sources of information to identify ML/TF risk factors and the list is of a non-exhaustive nature.