AML software for art dealers and high-value dealers

• Agents and intermediaries: buyers often act through advisers, galleries or family offices, so the person you must know may be one step behind the person you deal with.
• Opaque ownership: works are frequently bought and held through companies, trusts or foundations.
• Value without movement: an object can change owner while staying in storage, which removes the shipping event many controls rely on.
• Cross-border sales: a seller, a buyer and a storage location in different jurisdictions can mean several sanctions regimes in one sale.
• Both sides of the sale: the seller and the provenance of the object matter as well as the buyer and the source of the money.
• Speed of the sale room: decisions made at a fair or an auction still have to leave a file behind them.

1. 1

   Know when the rules apply

   Identify which sales, by value and by payment method, bring the business inside national anti-money laundering rules, and register with the supervisor where that is required.

2. 2

   Identify buyer, seller and owners

   Customer due diligence on both parties, including the person behind an agent and the beneficial owners of any company or trust.

3. 3

   Screen before the sale completes

   Sanctions and PEP screening of buyer, seller and intermediaries before the sale is concluded or the object released.

4. 4

   Apply enhanced due diligence

   Source of funds and source of wealth checks, and senior approval, where a party is a PEP or the sale is otherwise higher risk.

5. 5

   Record and report

   Keep the evidence of each check and report suspicious activity to the financial intelligence unit.

FATF Recommendation 22 names dealers in precious metals and stones among the designated non-financial businesses and professions when they engage in cash transactions above a designated threshold. The FATF standards do not name art dealers as such, but many jurisdictions have brought the art market into scope nationally.

In the UK, the Money Laundering Regulations 2017 cover art market participants for transactions at or above a set value, and require them to register with HMRC; high-value dealers who accept large cash payments are also covered and supervised by HMRC. In the EU, persons trading in or acting as intermediaries in the trade of works of art, and traders in goods who accept large cash payments, are obliged entities under the EU anti-money laundering framework above stated values. Sanctions apply to every sale regardless of value, and some sanctions regimes also restrict trade in luxury goods with targeted countries.

• Screening of every party: buyer, seller and agent in one check, from the portal or an API.
• Ownership checks: a company lookup that reaches the owners behind a buying vehicle and screens them.
• PEP coverage that reaches family and associates: high-value assets are often held in a relative's or associate's name.
• Explainable matches: each alert shows which list and record matched, so a busy sale room can clear namesakes.
• Re-screening of repeat clients: collectors and dealers you work with regularly checked again when lists change.
• Evidence for the file: a record of when each party was screened and what was found.