My Lords, I am grateful for the Minister’s response to the amendments I tabled, supported by my noble friend, on the need for the publication of timely guidance on how the schemes will operate. He has been true to his word from the first day of Report and taken away many of the issues raised in Committee and come back with a number of amendments to address them. They relate mainly to the next group and the political tier but, given that my amendments fall within this group, I wish to put on record how grateful I am to him for the way in which he has engaged and responded.
The government amendments have addressed many of the significant concerns of those seeking legitimate activity—I see that the noble Baroness, Lady Noakes,
who raised the issue of economic activity, is in her place—and those concerned about human rights. The areas where some questions remain include those we raised on the first day of Report, such as the German Stiftungen and other organisations that will not fall within the scope of the FIR schemes but are nevertheless concerned that they may do so. Much of that will be resolved in the guidance provided to them and therefore, the timeliness of that is of utmost importance.
In Committee I quoted at length from the Government’s impact assessment of the Bill, which suggested that the initial scheme could cost up to £48 million and many thousands of people would have to be informed about the scheme’s operation. Given that it is to be welcomed that the Government have reduced the scope of that, I am not sure what status the impact assessment now has. I should therefore be grateful if the Minister told us whether the guidance to be provided will also be informed by some revision of the impact assessment.
There will be businesses wanting to carry out legitimate activity that have to operate under a set of rules in the current regulations on countries at risk of money laundering or financing terrorism—we have a list of over 30 such countries—and there may now be an enhanced tier under FIRS. There will also be others, making it quite a complex environment for businesses operating in the political sphere.
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I am grateful to the Minister for stating that the regulations to establish the scheme will not be put in place until guidance has been issued. It would be helpful if he could state categorically that there will be enough time after the guidance has been released before the scheme becomes operational. There is no point in guidance being published a week before it is operational. Many people will need to familiarise themselves with it, and their knowing that they are not part of it is as important as knowing that they are. If the Minister could take the opportunity to be crystal clear about the Stiftungen, that would tidy up some loose ends. I am grateful for the way in which he has approached this.