AML Training: A legal requirement for Art Market Participants

September 15, 2021
by ArtAML Team

If you were thinking that reading AML guidance was enough to satisfy the requirement to have training, think again.

Continuing to trade at the level of 10,000+ Euros as an Art Market Participant carries serious responsibility in the modern marketplace.

Let’s start with a common misconception:
AML Training is separate to ArtAML (or any other) platform onboarding. Learning how to use a technology solution to help with your AML needs will not satisfy authorities in the case of an audit.

Here’s what the BAMF Guidance (2020) states as being required:

Part I: Overview
42. Delivery of staff training should be carried out in a clear and effective way, and repeated sufficiently often, including when new employees join the firm, when roles change, or when regulations, policies or procedures change. Training may be provided by internal or external compliance experts in many formats, including face-to-face, on-line or via seminars and conferences.
44. AMPs should maintain records of training and may be asked to produce evidence of training to HMRC. 

Part II: Guidelines
4.10  The content of any training, the frequency of training and the assessment of competence following training are matters for each AMP to assess and decide in light of the money laundering and terrorist financing risks they identify, provided the requirements of Regulation 24 are met. HMRC will expect such issues to be covered in each AMP’s policies and procedures. 

4.11  For example, policies and procedures should make provision for the attainment of an appropriate competence level by the relevant employees identified in paragraph 3.9, prior to them undertaking the duties for which they will be responsible. This may, for example, be achieved by the attainment of an appropriate pass rate in a competency test following training. 

4.15  Ongoing training must be given to all relevant employees at appropriate intervals. Records should be maintained to monitor who has been trained, when they received the training, the nature of the training and the effectiveness of the training.
7.19 An AMP’s records should include:
(a) in relation to training:
> dates AML training was given;

> the nature of the training;

> the names of the staff who received training; and

> the results of the tests undertaken by staff, where appropriate.

How can you get AML training specific to the needs of the art market while passing a test (as above) and receive paperwork?

We have you covered. ArtAML’s training program is specifically geared to the art market and includes a comprehension test in addition to a digital certificate (providing that you pass the course). As the best practice for frequency established across regulated sectors is once a year, the ArtAML Certificate of Completion is valid for one year.

Find out more about our AML Training program.

Before you go… be sure that internal training relates specifically to your business’s AML Policy:

It’s important that you and any other ‘relevant employees’ (including independent contractors involved with AML in transactions) are aware of how the business addresses identified risks, outlined in your ‘Policies, Controls and Procedures’ (PCPs) as contained within your business’s AML Policy. Anytime that a risk changes, a review is to be taken of the AML Policy, with a view to updating mitigations if needed (for example, if a new risk doesn’t have any procedure to address the risk in real-life transactions).

Therefore, internal training keeps relevant employees up-to-date with the business’s specific needs, while certified AML Training provides the thinking behind AML to support your overall compliance (for instance, learning how to take a risk-based approach and understanding how art businesses are specifically at risk of being the target of money laundering or terrorist financing activities).

Sort out your AML Training:
Find out about our training and get started right now. Once purchased, it will take about 2 hours, and you can pause, re-start, etc.

Further reading:
Risk assessment and AML Policy: A legal requirement for Art Market Participants

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