Our unique combination of legal, regulatory, business development and art market expertise grants Corinth a special insight, not only into the relevant international legal landscape, but also the realities and pressures facing art market participants. We offer competitive prices with fast turnaround times.
• Corinth tailors its services to each client’s needs. These include, setting up and implementing a comprehensive AML Compliance program, which includes conducting and documenting a Risk Assessment, writing bespoke AML Policies and Procedures, conducting training for all staff and, often, registering with local authorities. Corinth manages to accomplish the above on a tight deadline whilst offering a highly competitive price.
• We provide AML guidance in connection with individual transactions, often for more complicated international transactions with different jurisdictions.
• We consult with businesses providing guidance on the unique nature of art market AML compliance
• We assist art market participants with government inquiries
• Based on first hand experience with Suspicious Activity Reports, we support clients filing SARs
Risk Assessments
• The annual overall business Risk Assessment is a requirement imposed on art market participants in the United Kingdom. Our Risk Assessment seeks to uncover the risks involved for staff and business of money laundering, terrorist financing and proliferation financing.
• Corinth collaborates closely with art market participants to prepare a bespoke, accurate Risk Assessment.
Policies, Controls & Procedures
• To ensure the risks identified through the Risk Assessment are addressed, Corinth assists with the creation of bespoke AML Policies, Controls & Procedures.
• Corinth works closely with clients to develop procedures and systems to support, not strangle the business.
• We annually review your AML Policy in response to the updated Risk Assessment
Money Laundering Reporting Officer (MLRO)
• When choosing an MLRO, Corinth provides guidance which takes into account the credentials as well as provides support for an MLRO through detailed training
• Corinth guides MLROs in their responsibilities, which include:
o Developing and managing an effective AML Program, including policies, controls & procedures
o Acting as the liaison for third-party enquiries, such as HMRC
o Receiving and assessing staff reports of potentially suspicious activity
o Filing Suspicious Activity Reports (SARs) with the National Crime Agency
o Fulfilling customer due diligence obligations
o Exploring Red Flags
o Enabling staff awareness
o Reporting to Senior Management
• Corinth collaborates with MLRO during regular audits of AML Compliance Programs to identify potential gaps or weaknesses in existing controls and procedures that may require adaptations to changing risk scenarios
• Record Keeping supervision is an important element of MLRO responsibility. Corinth provides MLRO support to ensure that adequate record keeping and decision-making policies and processes are in place
Training of New and Existing staff
• Corinth has a training program which highlights the main risks presented by the unique structure and client base of each business
• Training is tailored as appropriate for front line sales teams interacting with clients, for the senior management who bears the responsibility for the business’ AML compliance, and for MLROs who have implementation responsibilities, such as deciding if and when to file a suspicious activity report
• New staff or staff who change roles or responsibilities require training to alert them of the risks inherent to their new role
• Annual refresher training is important for all compliance programs. Based on recent changes in the regulations and laws or other risks, issues or concerns, Corinth develops refresher training to ensure staff are made aware of changes in the AML landscape as well as to remind staff of ongoing risks and obligations
Facilitate HMRC registration
• Art market participants are required to register as such with Her Majesty’s Revenue and Customs (HMRC). This obligation extends to participants with operations in the UK or those temporarily participating in the UK market through a fair. Corinth offers help with clients’ application process.
Technology Solutions
• We share our knowledge of art market AML tech solutions, to find the best option for your business in terms of size and scope.