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 Acitivty Reports, we support client’s filing SARs
- We provide general art market business advice
- The Risk Assessment seeks to uncover the risks involved for staff and business of money laundering.
- 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, transactions and the subsequent 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.
- We help you keep your AML Program compliant by conducting annual Risk Assessments, which uncovers risks resulting from changes in your business or the regulatory framework.
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 as well as reviews and comments on any existing 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:
- 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 (SARs) with the National Crime Agency
- Fulfilling client identification and verification responsibilities
- Exploring Red Flags
- Enabling staff awareness
- 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
- 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
- Corinth develops 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.
- We share our knowledge of art market AML tech solutions, to find the best option for your business in terms of size and scope.
- We provide general art market business advice.
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
We at Ewbank Auctions were delighted with Corinth Consulting. After a free initial consultation, we signed up and were able to leave all the work to Rena and her expert team. There is no time to lose because AML is mandatory and on current timetables must be set up by June 2021.
Chris Ewbank, FRICS ASFAVEwbank Auctions
Rena’s great skill is not only to make compliance understandable but also to introduce working practices that are effective, both for the organization and the for the regulatory authorities. In short, Rena gets it done, whilst protecting and enhancing business prospects.
Robin Woodhead, former CEO and Chairman, Sotheby’s InternationalRobin Woodhead
Paula brings all the skills and abilities to the table to set up an effective Anti-Money Laundering programme. She is exceptionally good at managing complex projects and implementations while maintaining a constructive and open dialogue with all stakeholders. It was a true pleasure working with her.
Alessandro Fiorotto, Managing Director Art FinanceGurr Johns Capital
Paula has been a true asset to the team during the implementation of the 5th European Anti-Money Laundering Directive. She was excellent in managing projects as well as engaging with internal and external parties. Paula is a very inquisitive and collaborative person and I enjoyed working with her enormously
Karen Smith, Director of Operations and MLROThe Fine Art Group
I have known Rena Neville since the time we were both in private practice in New York, following which she flourished in her multi-faceted roles at Sotheby’s, most notably overseeing its engagement with the range of complex regulatory and other compliance issues that arise in the international art market. And as Chairman successively of two major artist foundations, I continue to have a deep awareness of the operations of that market. Throughout, I have known Rena to be an astute and strategic thinker, holding to the highest ethical standards and likewise commanding great respect in her profession.
Michael Straus, ChairmanRobert Rauschenberg Foundation
Having been in the art market for most of her career first as a lawyer, then as compliance director and later in business development, Rena brings a comprehensive understanding of the market and helpful insights on how to address the challenges inherent in art market regulation and compliance.
Daniella LuxembourgLuxembourg & Co
In today’s fast changing global art world, it is essential to have access to the type of expertise and advice Corinth Consulting offers. Rena Neville brings a wealth of knowledge and experience in these areas but it is her valuable, creative approach in finding practical solutions that is an asset to any client and their business.
Matthias Arndt and Tiffany WoodArndt Art Agency
Having known Rena for many years, she has broad, international experience of the complex legal issues facing dealers and specifically, the complexities and risks involved in implementing a compliance program. In my experience, she is not only qualified to help set up AML Compliance, but is easy to work with.
Jonathan GreenRichard Green
I have worked with Rena Neville over many years and I have always been impressed by her extensive practical knowledge of the art market and its legal and regulatory framework.
Anthony Brown, ChairmanBritish Art Market Federation
Rena Neville was a key figure within the firm during my time as a non executive Director and Deputy Chairman of Sotheby’s [1994-2019]. She was completely reliable and a pleasure to work with. For me as a layman in the arcane but crucial world of money laundering compliance, she had the unusual ability to make a complicated issue simple, but without removing the essential nuances. Based on my knowledge of Rena Neville I would be very happy to seek her professional advice.