Question 1

Which dealers are AML-regulated?

Accepted Answer

Dealers in goods accepting cash payments above a threshold are obliged entities in the EU (€10,000 cash threshold under the AMLR, with member-state options to lower) and UK (HMRC supervision, €10,000 threshold). The art market: the UK extended AML obligations to art market participants in January...

Question 2

What are the key risks in the art market?

Accepted Answer

Subjective valuation, opacity of buyers and sellers (use of intermediaries and freeports), historical anonymity norms, cross-border movement, and ease of physical concealment of value. Free-port storage in jurisdictions like Geneva, Luxembourg, and Singapore has been a particular focus of regulat...

Question 3

What about luxury goods and watches?

Accepted Answer

Luxury watches, jewellery, and high-end vehicles are repeatedly identified by FATF and national regulators as cash-conversion vectors. Cash-payment thresholds and dealer obligations vary widely; the EU AMLR brings dealers in goods receiving cash above the threshold into scope, and several member...

High-value goods dealers (art, precious metals, luxury)