High Value Goods Dealers
USA, UAE sign bilateral cooperation agreement against terrorism, transnational and cybercrime.
U.S., U.K., E.U. to remove selected Russian banks from the SWIFT system.
NZ Ministry of Justice calls for submissions to review the country’s AML CFT Law.
Central Bank of Oman and NCFI cooperation agreement to enhance AML CFT information sharing.
Negligence, lax reporting habits, opaque practices, understaffing and underestimation of the potential of criminal abuse have so far kept the High Value Goods and the Arts Market a side note for regulation. However, the attraction of stolen wealth, officials of corrupt regimes, money launderers to the luxury and the arts sector has never been a secret – with more and more governments starting to tackle “grand corruption”, the tide is turning. HVG is one of the industries the regulators will increasingly target, and for sound reasons.
The Turn of the Tide
There is no doubt that due diligence standards are heightening for the sector, the investigative lens will get sharper. After U.S. regulatory focus shifting toward shifting of the regulatory focus in the U.S., the investigation of “secret purchases” by illicit personae, and the 2020’s UK Government National Risk Assessment that singled out the art market participants from the HVGD businesses, it is certain that several governments will tackle the involvement of High Value Goods market in “grand corruption”.
The U.K. High Court in England and Wales are authorised to issue Unexplained Wealth Orders (UWOs), enabling the investigation of past transactions, compelling the parties to submit the documentation of the agreement that do not meet the standards and recover the damages. UWOs are a regulatory instrument that work in retrospect and can unearth the details of a property or good acquired, demanding the full explanation and documentation of the acquisition.
Don’t end up a conduit for “Tainted Treasures.”
Investigative journalism triumphs such as Pandora Papers and Panama Papers have illuminated, more than once, how high value goods and the arts market have been exploited by criminals and corrupt leaders of oligarchic regimes. High value goods and works of art purchased through shell companies, laid to sleep in specially designed repositories, turn out at the integration phase of money laundering operations – they enable kleptocrats and illicit actors, prestige, a faux-standing in high society, and the benefit of the sales value of the assets and goods they own. Meanwhile priceless historical artifacts in failed states and war-torn countries are known to have been used to finance terrorist organisations. Geo-political crises will not extract from the momentum of new regulations, given the markets gravitating the officials of corrupt regimes, investigations will turn stricter, more demanding.
Adopt a custom Risk-Based Approach
Don’t let lack of awareness or understaffing ruin your business. Adopt a RBA
proportionate to the size and goals of your business.
Thorough UBO Checks
Don’t end up a conduit for “Tainted Treasures”. Know your customers, fight financial crime in your domain.
Keep track of your transactions and client data, utilise Sanction Trace’s document retention capacities.