Corinth offers services consistent with the requirements of the UK Anti-Money Laundering, Terrorist Financing, Anti Bribery & the Proceeds of Crime Act 2002 law and regulations (collectively, the ”AML Laws”). The services are available to regional and international branch offices of UK art market participants.
● Risk Assessments
- Corinth collaborates with businesses in conducting their AML Risk Assessment. Corinth provides its clients with a Risk Assessment Questionnaire to assist in identifying and assessing potential AML business, transaction and client risks to which the participant may be exposed.
- Corinth reviews the preliminary results of the Risk Assessment and works with clients to help them complete a Final Risk Assessment and written record of the assessment conducted, including identifying the level of the specific risks confronted by the client.
● Policies, Controls & Procedures
- to ensure the risks identified in the risk assessment are addressed, assist with creation of bespoke AML Policies, Controls & Procedures as well as review and comment on any existing AML Policies, Controls & Procedures.
- Work closely with clients to develop procedures and systems to support, not strangle the business
● Money Laundering Reporting Officer (MLRO)
When choosing an MLRO, Corinth provides guidance considering the credentials and support for an MLRO as well as the extent of training for the individual MLRO
- Corinth guides MLROs in their responsibilities including
– Developing and managing an effective AML Program, including policies, controls & procedures
– Acting as the liaison for third-party enquiries
– Receiving and assessing staff reports of potentially suspicious activity
– Filing Suspicious Activity Reports with the National Crime Agency
– Fulfilling client identification and verification responsibilities
– Exploring Red Flags
– Enabling staff awareness
– Reporting to Senior Management
- Collaboration 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 adequate record keeping and decision-making policies and processes exist
- Record Retrieval guidance is provided to facilitate easy and prompt record retrieval in the event of an audit by Her Majesty’s Revenue and Customs
● Training of New and Existing staff
- Develop training that highlights key 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, to senior management who bear the responsibility for the business’ AML compliance and for MLRO’s 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 to the risks inherent in the new job or 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 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. This obligation extends to participants with operations in the UK or those temporarily participating in the UK market through a fair. Corinth offers help in clients’ application process.
Money Laundering Reporting Officer Support
What the law says…
Scope of Corinth’s Services
Corinth is not providing legal or commercial advice nor is Corinth responsible for the appropriateness of any legal, commercial or strategic decisions taken by Clients. The services reflect relevant law and regulation at the time the services are provided. Corinth and its directors accept no responsibility for legal advice or for the consequences of a change of law or regulation after services have been provided