Intervention Support

Has the regulator been in touch to arrange a visit or remote call to discuss your AML compliance program? You have an intervention in the coming weeks.

Having an intervention is a wake-up call for Art Market Participant businesses. The purpose from the regulator’s point of view is to 1) determine if regulated businesses are meeting compliance obligations; 2) support AMPs to understand what is required; and 3) determine if the business has been facilitating economic crime.

Intervention outcomes are: 1) No further action; 2) Advisory letter; 3) Warning letter (for being in breach of the regulations); or 4) Escalation, potentially leading to a tribunal, fine and criminal conviction.

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.

This service is presently available to UK businesses who have been using our CDD solution 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.

This 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.

Fee per intervention £595
Cover with a subscription to ArtAML™ Protection at £17.50 / mo.

Get in touch with our Support Team to find out more and proceed with Intervention Support or ArtAML™ Protection.

AML Training
ArtAML Training
ArtAML Training

ArtAML™ training on-demand was extremely helpful and informative. The structure of the course works very well when trying to fit it into a work day, allowing you to pause and return to each section when you have time. It was presented clearly and used very helpful ‘real world’ examples to put certain regulations into context. I would certainly recommend this training course to other galleries.

Katie Burness
Director of Communications and PR
Cadogan Contemporary

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