AML Policies, Controls & Procedures
Considering the results of the Risk Assessment, Corinth creates for our Clients bespoke AML Policies, Controls & Procedures consistent with the UK laws relating to: Anti-Money Laundering, Terrorist Financing, Anti Bribery & the Proceeds of Crime Act 2002 (the “AML Laws”).
As such, the Policies, Controls & Procedures cover a wide range of topics from understanding money laundering and terrorist financing to guidance for conducting Client Due Diligence and recognizing potentially suspicious activity, known as Red Flags.
AML Record Keeping Policies & Procedures
The UK government is entitled to conduct audits of an art market participant’s AML Compliance Program.
Examples of information that may be audited include information on staff training, client identification and verification and Suspicious Activity Reports that may have been filed with the National Crime Agency.
Thus, it is important for the Client to
- properly document their compliance with the AML Laws and
- be in a position to promptly retrieve the relevant information and
- produce the records in an organized fashion.
Corinth provides guidance on Record Keeping Policies and Procedures as well as document retrieval.
The purpose of a Risk Assessment is to identify, measure, monitor and control risks. Risk Assessments seek to uncover risks to our Client’s in light of the UK laws relating to: Anti-Money Laundering, Terrorist Financing, Anti Bribery…
Her Majesty’s Revenue & Customs (HMRC) Registration Corinth will explore whether an art market participant qualifies for registration with HMRC. If so, Corinth will review with the client whether they have fulfilled their obligations to satisfy registration…