ICA Specialist Certificate in Anti Money
Laundering and Art Syllabus
Essential AML Concepts • UK market regulation – the HMRC
• US market regulation
• What is money laundering? • China and the Asia-Pacific market regulation
• How is money laundered? • What is the ‘art market’?
• Placement • Meeting the aims of regulation
• Layering
• Integration
• Limitations of the three-stage money
Money Laundering Risks in the
laundering model Art Market
• Identifying suspicious activity
• Customer due diligence (CDD) • Anonymity and secrecy in the art market
• The value of CDD information • Trusts and beneficiaries
• Enhanced due diligence (EDD) • Foundations and charities
• The risk-based approach • Art buyers, consultants, advisers and other
• Money laundering and terrorist financing intermediaries
• The subjective, yet high, value of art
• Forgery, fakes and confirmation bias
The Art Market – A Summary • Employee risks
• Customer risks
• Types of distribution in the art market • Customer identity
• The primary and secondary markets • Falsifying documents
• Auction houses • Identity and substitution
• Art dealers and private galleries • Means of payment risks
• Art fairs • Cash and ‘structuring’
• Art intermediaries • Client accounts and ‘reliance’ in
• Free ports intermediated purchases
• Digital art and non-fungible tokens (NFTs) • Renting art
• The legal and regulatory context for the • Repeated and long-term payments to free ports
art market • Payments to/from fronting or ‘shell companies’
• Financial Action Task Force (FATF) and the • Payments to/from ‘high-risk jurisdictions’
art world • Art financing
• Industry codes - The Basel Art Trade guidelines • Online art dealing risks
• Industry Codes – Responsible Art Market • False identity
guidelines • Use of third parties - ‘mules’
• Industry Codes - British Art Market • PEPs/sanctions/high-risk countries
Federation guidelines • Opening multiple customer accounts
• EU Directives – Fifth & Sixth EU Money • Large transactions
Laundering Directives • Private sales facilitated by dealers
Mar 20 – ICAB15403-6
• Use of online client accounts AML in Operation
• Auction house Internet bidding and
pre‑sale deposits • Anti money laundering controls
• Digital sales and non-fungible tokens • Regulatory context – legal expectations across
borders and through value chains. ‘Reliance’.
• Customer onboarding
Risk-Based Approach, • Practical tools for customer review
Culture and Governance • In-person based client onboarding
• Online
• What is a risk-based approach? • Performing CDD in different art market
• Implementing a risk-based approach transactions
• Risk assessment – assessing money laundering • Source of wealth/source of funds
and terrorist financing risks • Politically exposed persons (PEPs)
• Different approaches to developing a risk • High-value customer risks
assessment • Press speculation
• Root cause analysis - what went wrong and • Complex offshore structures or layered
what can we do about it? companies
• Fishbone and ‘five whys’ analysis • High-risk jurisdictions
• Foresight and emerging risk • Tax issues
• Risk appetite • Money service businesses (MSBs)
• Mitigating money laundering and terrorist • Other art market participants
financing risks • Facilitation (grease) payments
• Culture and conduct • Transaction monitoring
• AML governance • Maintaining CDD
• Policy
• Three lines of defence
• Senior management engagement
• Training
• Recordkeeping and management information
• Monitoring and quality assurance
• Remediation
Mar 20 – ICAB63-1540
