ArtAML™

Here is your November update on the GBP to EUR conversion rate for qualifying art market transactions. As an Art Market Participant, you are required to complete due diligence checks on any cumulative transactions (including VAT and additional fees) that meet or exceed the threshold of 10,000 EUR. In November 2024, the €10,000 threshold converts to £8,444.51 using the Bank of England Daily Spot exchange rate. To stay compliant with AML obligations, bookmark the #ArtAML Knowledge Hub for monthly updates on rate fluctuations and qualifying thresholds. #AML #ArtAML #ArtMarketAML

Supervised Business Register (UK) If you're a UK Art Market Participant ("AMP") transacting with another AMP in the UK and the overall transaction qualifies for AML (€10K in works of art), the other business must be registered with HMRC to proceed with the transaction. See the most recent list https://buff.ly/4cpA2hx #AML #ArtAML #ArtMarketAML #AMLcompliance

In the fight against financial crime, it’s important to understand the key organisations involved in maintaining compliance. One such organisation is the National Crime Agency (NCA), which plays a vital role in the UK’s efforts to prevent money laundering and protect businesses. #AML #ArtAML #ArtMarketAML #AMLFAQ #antimoneylaundering #protectyourbusiness #nationalcrimeagency #AMLcompliance The information provided in this post is based upon ArtAML™’s expertise in AML for the art market. More details can be found via artaml.com and any further information sought can be requested via our contact page or contact@artaml.com. The content in this post does not constitute legal advice and is not to be relied upon as such. Independent legal advice should be sought depending on your specific needs.

It's a delight to receive such wonderful feedback from @Jack Trodd 🙌 We pride ourselves on providing exceptional guidance, education, and support to our clients in the niche space of AML for the art market. From the very first enquiry to every interaction thereafter, our team is dedicated to supporting your compliance and thereby helping you to carry on doing the work that you love. #AML #ArtAML #ArtMarketAML #AMLcompliance The information provided in this post is based upon ArtAML™s expertise in AML for the art market. More details can be found via artaml.com and any further information sought can be requested via our contact page or contact@artaml.com. The content in this post does not constitute legal advice and is not to be relied upon as such. Independent legal advice should be sought depending on your specific needs.

In today’s complex financial landscape, knowing your customer (KYC) is more important than ever. Verifying a person’s identity not only helps in complying with AML regulations but also protects your business from potential fraud and reputational damage. Understanding the necessary documents for identity verification is the first step in safeguarding your organisation and ensuring a secure business environment. Take the time to educate yourself and your team about these requirements to build trust and credibility with your clients. If you would like further clarity on this topic, please get in touch https://buff.ly/4euwP22 #AML #ArtAML #ArtMarketAML #AMLFAQ # #antimoneylaundering #protectyourbusiness The information provided in this post is based upon ArtAML™’s expertise in AML for the art market. More details can be found via artaml.com and any further information sought can be requested via our contact page or contact@artaml.com. The content in this post does not constitute legal advice and is not to be relied upon as such. Independent legal advice should be sought depending on your specific needs.

How AML compliance has changed for art businesses: 2018-2024 👏 As we celebrate our sixth birthday this month, we take a look at the changing landscape of AML in the art market. This considers two aspects for each year covered: 1) legislation and implementation; and 2) our evolution to meet needs. We are here every step of the way to guide your Art Business through the process of AML due diligence. To see how we can support you, get in touch or book a demo. Links in bio

Do you know what proceeds of crime means? It's a term that's vital to understand, especially in industries vulnerable to money laundering, like the art market. The image below explains what it means and why it’s important. Take a moment to consider how this might impact your business and the steps you can take to stay compliant. #AML #ArtAML #ArtMarketAML #AMLFAQ #proceedsofcrime The information provided in this post is based upon ArtAML™’s expertise in AML for the art market. More details can be found via artaml.com and any further information sought can be requested via our contact page or contact@artaml.com. The content in this post does not constitute legal advice and is not to be relied upon as such. Independent legal advice should be sought depending on your specific needs.

Recently, in a period of several days, five ArtAML™ clients informed us about their banks performing detailed AML audits. Why? Banks have generally determined that businesses transacting in art are high-risk.   This is resulting in annual AML audits, in which you need to: ⚡ provide an up-to-date AML Risk Assessment & Policy (with policies, controls and procedures); ⚡explain how you would submit a Suspicious Activity Report ("SAR"); ⚡answer a number of questions that evaluate your compliance program (often including training taken amongst many other points) and test your acumen; and  ⚡in some cases, provide information on how you conducted CDD.   Be warned: You might need to educate the bank manager on how AML applies to the sector. We've seen some banks request information on what CDD was conducted for transactions below the €10,000 threshold. Unless there was potentially suspicious activity, the need to conduct CDD would not have applied.     Another word of caution is to be cognisant of data protection. We've heard of some requests for personally identifying information ("PII") that has been collected by the Art Market Participant ("AMP"). However, the bank is not legally required to also have copies of that information. Our understanding is that banks have accordingly accepted that data laws don't permit AMPs to transfer such personal data to them. It's still possible for the bank to establish what CDD was performed for differing transactions of interest.    As for documents required by banks, our Compliance Team can deliver them on an expedited basis. However, be aware that if your business is regulated for AML, you have a legal requirement to have these in place dating back to when legislation took effect.    Get in touch if you require support with a bank's AML audit or want to learn more https://buff.ly/3Zy4QKi .

The term 'Know Your Customer' - or, as we like to say, 'Know Your Collector' 😉, is used a lot for AML compliance. But what does it really mean? Note: There is more to Customer Due Diligence ("CDD") than taking this step: There are also transactional considerations that must be risk assessed and recorded. Simply taking a photo ID and possibly proof of address does not meet AML compliance requirements for qualifying transactions. Click on the carousel images to reveal the answer. #AML #ArtAML #ArtMarketAML #KYC #CDD #AMLFAQ The information provided in this post is based upon ArtAML™s expertise in AML for the art market. More details can be found via artaml.com and any further information sought can be requested via our contact page or contact@artaml.com. The content in this post does not constitute legal advice and is not to be relied upon as such. Independent legal advice should be sought depending on your specific needs.

While Russian TV presenter Dimitri Simes has been indicted by the U.S. for violating sanctions and money laundering, his wife Anastasia has been charged with buying arts and antiquities for a sanctioned Russian oligarch, Aleksandr Udodov. Anastasia purchased works from galleries and auction houses in the U.S. and Europe. After storing pieces in their home in Virginia, they were shipped onward to Russia. This brings to mind the Luxury Goods Ban and how it varies between jurisdictions: In the UK, businesses are not to transact with someone purchasing a luxury good priced at £250+ if its destination is Russia or Belarus and/or if the buyer is "connected with" Russia or Belarus. In the U.S. and EU, the focus is only on the destination (at any value for the U.S. and €300 for EU). In this situation, businesses presumably identified the destination as the Virginia residence. However, that was not the ultimate destination of art. This is an evasion of sanctions and makes sense of the UK's wider scope for the Luxury Goods Ban. Circumvention is the name of the game for individuals involved in economic crime. Read the full piece via https://buff.ly/4ecbha6 See our Knowledge Base article on the Luxury Goods Ban via https://buff.ly/47l1AnA #luxurygoodsban #artaml