Your art business’ wake up call

To date, the most severe outcome we’ve seen is warning letters, which have not been accompanied by penalties. They provide information of the regulatory breach, the related clauses in legislation and how to rectify. Your business is required to implement remedies by a set date. Then at a later date, the regulator will check in to attain your most recent AML Risk Assessment and Policy and is subject to ‘testing’ more recent transactional compliance conducted. Should the business still not be meeting requirements, a penalty might be levied.

Intervention Support is part of ArtAML™ Protection. This service is only available to UK businesses who are already signed up for our wider AML compliance program with a CDD Lite, CDD Trade, CDD Plus or CDD Team subscription plan for a minimum of six months. If your business is based in another jurisdiction and is using our CDD solution, we will be glad to provide pro-bono support as was initially done in the UK.

Add ArtAML™ Protection 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 ArtAML™ Protection.

Our Intervention support service includes:

• A preparatory call (typically 1 hour and up to 1.5 hours) will cover what to expect and how to prepare for potential curveball questions. A recording will be provided to the business for reference and potential sharing with any colleagues as applicable.
• Our Compliance Team will refresh your AML Risk Assessment & Policy (if already done by ArtAML™).
• We will provide any CDD support required in the lead up to the intervention. A tidy-up to ensure all Ts have been crossed and Is dotted is prescient for CDD testing that takes place during the intervention. Occasionally, this review helps to identify what might be suspicious activity, as many art businesses did not initially understand the legal requirement to report suspicious activity.
• Following the intervention, we will review the Notes of the Meeting (“NOMs”) and outcome letter (options typically being one of: No further action; Advisory; or Warning) and will provide feedback. The NOMs should be an accurate reflection of the meeting and a Warning letter should be issued for breaches of the ML Regulations.
• If deemed necessary, we will arrange a call to agree corrections for the NOMs and any other actions to be taken (typically between 30 mins – 1 hour).
• Occasionally, more follow-up support is required by our team. This is most often to assist with answering subsequent questions sent by the HMRC officer.