AML Risk Assessment and Policy
Did you know having these documents in place is a legal requirement?
Find peace of mind with our comprehensive AML risk assessment and corresponding policy. We simplify your AML Policy so you can concentrate on your business’ bigger picture.
Not only is it a smart idea to put these documents in place, for art businesses regulated for AML compliance it is a requirement under law, and one of the seven steps to becoming AML compliant.
Economic crimes in the art market?
The AML Risk Assessment identifies how your art business might be targeted by economic crime—namely, money laundering, terrorist financing and proliferation financing.
The resulting Risk Rating for your business is based upon objective methodology and covers the following five areas of risk:
- Customers
- Geography
- Products or Services
- Transactions
- and Delivery Channels
Helping your art business to mitigate risk
Our AML Policy outlines how your business is mitigating identified risks, making use of the ArtAML™ platform to take a risk-based approach. The Policy, with its controls and procedures, outlines the steps to take in order to mitigate the risks identified in the Risk Assessment.
AML Risk Assessment + Policy
£595 /year
equivalent to £49.59 /month
Our AML Risk Assessment Report includes:
- AML Risk Assessment and Risk Rating: to be made available to senior management
- AML Policy: to be made available to every team member, including customer-facing contractors
- Detailed documentation on how to perform Customer Due Diligence
- An Suspicious Activity Report (“SAR”) reporting template and guidance
- Glossary with acronyms and their corresponding meanings
- Appendices that include references, links for guidance, reporting and more
The AML Risk Assessment and Policy product is only available to businesses, wherever they are based, who are already signed up for our wider AML compliance program with a CDD Lite, CDD Trade, CDD Plus or CDD Team subscription plan. Having a CDD subscription is important, as the mitigations outlined in the policy are predicated on using ArtAML™ for the conducting of Customer Due Diligence. You will also be able to access our Risk Assessment module and download the full AML Risk Assessment Report from your dashboard on the ArtAML™ platform.
Add AML Risk Assessment and Policy when you purchase your CDD subscription, or get in touch with our Support Team if you’re already on a plan and wish to add AML Risk Assessment and Policy.
Seven steps to be AML compliant
In order to be approved as an Art Market Participant (“AMP”)in the UK—with equivalent guidance in other EU member states—it’s important that you:
Supervision
For jurisdictions where applicable (such as the UK), be registered for supervision as an Art Market Participant with the Regulator.
Nominated Officer
Appoint a Nominated Officer.
AML Risk Assessment & Policy
Have a business-wide AML Risk Assessment & Policy.
AML Training
Take, and keep up to date, AML Training to understand what you need to have in place and do to be compliant.
Customer Due Diligence
Conduct Customer Due Diligence (“CDD”) for qualifying transactions, also known as ‘relevant activity’.
Retain records
Retain records associated with CDD for a period of five years (using GDPR compliant storage for personal data).
Report suspicious activity
If any ‘suspicious activity’ is detected, regardless of value or a transaction proceeding, submit a Suspicious Activity Report (“SAR”) to the Financial Intelligence Unit (“FIU”) for your jurisdiction.
ArtAML™ is easy, simple and straightforward. Thank you so much.
Marianne Holtermann
Founder
Holtermann Fine Art