• Auctioneers and Brokers

    Some services provided by auctioneers and brokers in fine art, antiques, jewellery, watches and clocks are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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Auctioneers and Brokers

What are the ML/TF Risks?

Buying and selling high-value assets such as antiques, fine art, jewellery and watches are attractive for criminals because such transactions can avoid interaction with the financial sector.

In particular, these types of assets may be easily hidden and/or can be transferred to third parties with limited documentation.

Valuable assets of this type generally hold or improve their value if resold at a later date.

High-risk red flags include significant or frequent use of cash to purchase valuable commodities and assets, which can then be resold to disguise the origin of illicit funds.

Criminals may also buy high-value goods such as art, antiques, jewellery, watches and clocks then travel overseas with them to transfer value while avoiding detection.

Auctioneers and brokers in these assets must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/CFT laws.

What are the AML/CFT obligations?

In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:

  • Conduct a Money Laundering and Terrorism Financing Risk Assessment;
  • Develop an AML Program that is proportionate to ML/TF Risks;
  • Establish effective Board and Senior Management oversight of the AML/CFT Program;
  • Appoint an AML Compliance Officer;
  • Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
  • Implement a ML/TF Risk Awareness Training Program for staff;
  • Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
  • Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
  • Establish Record-keeping controls; and
  • Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for the auctioneer and brokers of fine art, antiques, jewellery, watches and clocks.

Our solutions deliver all the foundational AML/CFT materials including a ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.

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