Furthermore, dealers and auction houses in countries such as the US are not subject to anti-money laundering requirements.
Learning curve
It is no surprise that private schools and the newly regulated are still a way from developing a full understanding of money laundering. Assessment of risk, knowledge of techniques and refinement of safeguards is an ongoing process.
For the uninitiated who are used to selling a product a certain way, it can be a steep learning curve. Training of frontline employees so they can identify risk factors specific to that sector is critical.
A question also arises as to whether it is worth considering anti-money laundering regulation applying more broadly to businesses involved in the sale of high-value items, even when cash is not involved.
Alongside this, there is a need to encourage reporting of suspicions internally and to the National Crime Agency where appropriate, notwithstanding the culture of discretion in the world of high-end interests. There is a legal obligation to do so.
In 2019-20, the National Crime Agency reported that only 370 suspicious activity reports were submitted by high-value dealers, down 23 per cent compared to the previous year.
Although it may be that fewer businesses are accepting cash, the decrease is surprising when considering that demand for luxury goods is continuing and the risk of money laundering through gold, jewellery and cars remains.
Although there may be cultural norms when it comes to high-end sales, businesses involved cannot afford to turn a blind eye.
Anita Clifford is a barrister and principal associate at Bright Line Law
