SSPEs shall not be established in a third country to which any of the following applies:
((a))
the third country is listed as a high-risk and non-cooperative jurisdiction by the FATF;
((b))
the third country has not signed an agreement with a Member State to ensure that that third country fully complies with the standards provided for in Article 26 of the Organisation for Economic Cooperation and Development (OECD) Model Tax Convention on Income and on Capital or in the OECD Model Agreement on the Exchange of Information on Tax Matters, and ensures an effective exchange of information on tax matters, including any multilateral tax agreements.