AML Judgment Gap Report · Full findings
Property, Art and High-Value Dealers
This is a specimen. The cases, the weights, the methods and the sources are real, and are what your team would sit and what your own report would cite. The scores are invented, for a hypothetical cohort of 14 people. A real report carries your own results and nothing else.
Your team detects 1 of the 6 money laundering methods that apply to this sector. 4 need action, and 1 of those are rarely covered by standard training.
4 of these are urgent. Your team was tested on them and missed them.
Your assessment is 5 cases, not one. Each covers a different part of your exposure, and the appendix shows how many of your 6 methods each one carries. Measured against the methods that apply to this sector, not against other firms.
Since the last sitting
September cohort against March cohort. Your team detected 1 methods then and 1 now. 1 went backwards.
What to do
For each one, ask a single question. Does the team not know the method, or do they know it and have no rule that would surface it? The first needs a briefing. The second is a control gap, and it is the more serious answer.
- High
- Tested and missed, on a case covering a large part of your exposure.
- Medium
- Tested and missed on a smaller case, or never tested on one that matters.
- Low
- Never tested, and a small part of your exposure.
Ordered by priority. The reason for each is printed with it, so you can disagree with the ranking.
- 01
Art and Antiquities: self-dealing at auction
HighYour team was tested on this and missed it. It sits in The Private Client File, which covers 3 of the 6 methods that apply to you. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 3 of your 6 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Auction proceeds from a sale where consignor and buyer are ultimately the same interest, and valuations resting entirely on expert opinion where no non-destructive dating is possible.
90 days · Re-testSit The Private Client File again, on the version the team has not seen.
OwnerTarget date - 02
Fabricated Rental Income and Ghost Tenants
HighYour team was tested on this and missed it. It sits in The Private Client File, which covers 3 of the 6 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 3 of your 6 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Rent credits inconsistent with occupancy or utility data, tenants who never pay late, and payments originating from accounts connected to the landlord.
90 days · Re-testSit The Private Client File again, on the version the team has not seen.
OwnerTarget date - 03
Investment Migration and Residence Schemes
HighYour team was tested on this and missed it. It sits in The Private Client File, which covers 3 of the 6 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 3 of your 6 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Source of wealth evidenced principally by the qualifying investment itself, onboarding shortly after grant of status, and jurisdiction of residence inconsistent with any economic or family connection.
90 days · Re-testSit The Private Client File again, on the version the team has not seen.
OwnerTarget date - 04
High-Value Portable Goods
HighYour team was tested on this and missed it. It sits in The Goods Chain, which covers 1 of the 6 methods that apply to you.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 1 of your 6 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Dealer accounts taking third-party payments for goods delivered to someone else, part-exchange chains that never settle in cash, and customers whose purchases exceed any evidenced income.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date
On your own report
Each line carries your team’s result, an owner and a date. The re-test at 90 days shows what has moved.
Appendix
Evidence
Everything the finding above rests on, for anyone who wants to check it.
By case
The 5 cases that make up your assessment. Detection rate is the share of the laundering customer’s alerts the team caught. The last column counts people who escalated everything, which catches the laundering customer without deciding anything and scores badly for that reason.
| Case | Your methods | Share of assessment | Runs | Median mark | Detection rate | Escalated everything |
|---|---|---|---|---|---|---|
| The Private Client File | 3 | 44% | 14 | 49 | 45% | 3 of 14 |
| The Client Account | 1 | 14% | 14 | 87 | 84% | 3 of 14 |
| The Funnel Account | 1 | 14% | 14 | 78 | 76% | 2 of 14 |
| The Goods Chain | 1 | 14% | 14 | 45 | 42% | 2 of 14 |
| The Relationship Review | 1 | 14% | 14 | 50 | 46% | 2 of 14 |
Every method
All 6 methods that apply to this sector, and where each one is documented. Full citations are at amlbenchmark.com/coverage.
| Method | Case | Rate | Result |
|---|---|---|---|
| Art and Antiquities: self-dealing at auctionrarely trainedThe Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621), made 9 June 2026 and in force 30 June… | The Private Client File | 45% | Missed |
| Fabricated Rental Income and Ghost TenantsLetting agency businesses were brought into the UK regulated sector by the Money Laundering and Terrorist Financing (Amendment)… | The Private Client File | 45% | Missed |
| High-Value Portable GoodsHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraphs… | The Goods Chain | 42% | Missed |
| Investment Migration and Residence SchemesEuropean Commission v Malta (CJEU, Case C-181/23, judgment of 29 April 2025), holding that Malta's… | The Private Client File | 45% | Missed |
| Human Trafficking and Modern Slavery Proceedsrarely trainedFinCEN Advisory FIN-2020-A008, Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity (15… | The Funnel Account | 76% | Partial |
| Real Estate: engineered foreclosure and retained controlrarely trainedFinCEN's Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule, in force 1 March 2026 after a postponement… | The Client Account | 84% | Detected |
How this was measured
Each case is built around one customer who is laundering money. The rate is the share of that customer’s alerts the team caught.
- Detected
- Four fifths of them or more.
- Partial
- Between a half and four fifths.
- Missed
- Half or fewer.
- Untested
- No one has sat a case covering it.
Nothing is reported as detected on the strength of a good overall mark. Findings are suppressed below 3 runs on a case, because a smaller number describes one analyst rather than a team. Methods are declared on the case, not the individual alert, so this reports whether the team detected the method a case is built around rather than scoring each method separately.