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 9 of the 18 money laundering methods that apply to this sector. 6 need action, and 3 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 14 cases, not one. Each covers a different part of your exposure, and the appendix shows how many of your 18 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 4 methods then and 9 now. 5 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
Estate Administration and Probate
HighYour team was tested on this and missed it. It sits in The Relationship Review, which covers 6 of the 18 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 Relationship Review — covers 6 of your 18 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?
Estate funds arriving from a professional's client account with no visibility of their origin; assets appearing in an estate that the deceased's known circumstances do not explain; and a firm that is itself the executor, where no external party sees the administration at all.
90 days · Re-testSit The Relationship Review again, on the version the team has not seen.
OwnerTarget date - 02
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 4 of the 18 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 4 of your 18 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 - 03
Fabricated Rental Income and Ghost Tenants
HighYour team was tested on this and missed it. It sits in The Private Client File, which covers 4 of the 18 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 4 of your 18 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 - 04
Investment Migration and Residence Schemes
HighYour team was tested on this and missed it. It sits in The Private Client File, which covers 4 of the 18 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 4 of your 18 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 - 05
High-Value Portable Goods
MediumYour team was tested on this and missed it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 2 of your 18 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 - 06
Mirror Transfers and Daigou Purchasing
MediumYour team was tested on this and missed it. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 2 of your 18 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?
Card accounts repaid in cash or by unrelated third parties, purchase volumes far exceeding personal use, and paired domestic flows in two jurisdictions with no instrument connecting them.
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 14 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 Relationship Review | 6 | 22% | 14 | 49 | 45% | 3 of 14 |
| The Client Account | 5 | 17% | 14 | 87 | 84% | 3 of 14 |
| The Private Client File | 4 | 13% | 14 | 48 | 45% | 4 of 14 |
| The Policy Book | 3 | 10% | 14 | 87 | 83% | 3 of 14 |
| The Client Engagement | 2 | 7% | 14 | 91 | 89% | 3 of 14 |
| The Goods Chain | 2 | 7% | 14 | 45 | 42% | 2 of 14 |
| The Collection Network | 1 | 3% | 14 | 61 | 57% | 2 of 14 |
| The Disclosure | 1 | 3% | 14 | 85 | — | — |
| The Exchange Desk | 1 | 3% | 14 | 69 | 66% | 3 of 14 |
| The Funnel Account | 1 | 3% | 14 | 78 | 76% | 2 of 14 |
| The Onboarding Interview | 1 | 3% | 14 | 87 | — | — |
| The Securities Book | 1 | 3% | 14 | 53 | 50% | 3 of 14 |
| The Trade Corridor | 1 | 3% | 14 | 66 | 64% | 2 of 14 |
| The Verification Desk | 1 | 3% | 14 | 85 | 83% | 2 of 14 |
Every method
All 18 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 |
| Estate Administration and Probaterarely trainedSolicitors Regulation Authority, thematic review of probate and estate administration (13 December 2024): 25 firms visited, three… | The Relationship Review | 45% | Missed |
| Mirror Transfers and Daigou Purchasingrarely trainedFinCEN advisory on Chinese Money Laundering Networks (28 August 2025), identifying mirror transactions, money mules and… | The Goods Chain | 42% | 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 |
| Gold, Refining and Free-Trade Zonesrarely trainedUS Treasury (OFAC) press release of 25 June 2026 designating Gasabo Gold Refinery LTD of Kigali, its chairman Jean Malic Kalima… | The Trade Corridor | 64% | Partial |
| 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 |
| Bulk Cash Smuggling and Cash CouriersNCA press release of 28 May 2026 on a cross-border investigation across the island of Ireland: six arrests in Cookstown and the… | The Collection Network | 57% | Partial |
| Ghost Companies: struck off but still transactingrarely trainedNCA, 16 July 2025: 11,500 UK companies struck off the Companies House register following a multi-agency operation with Companies… | The Client Account | 84% | Detected |
| Loan-Back Arrangementsrarely trainedFATF, Professional Money Laundering (July 2018) | The Client Account | 84% | Detected |
| Necrofinance: dead directors and zombie accountsrarely trainedICIJ Panama Papers investigation (2016) into Mossack Fonseca | The Client Account | 84% | Detected |
| 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 |
| Synthetic and AI-Generated Onboarding Documentsrarely trainedFinCEN Alert FIN-2024-Alert004 (13 November 2024) on fraud schemes using generative AI to circumvent identity verification… | The Verification Desk | 83% | Detected |
| Beneficial Ownership ObfuscationThe two largest beneficial ownership regimes moved in opposite directions within a year, and a structure is now easier to hide in… | The Policy Book | 83% | Detected |
| Cash-Intensive Front BusinessFCA v National Westminster Bank (2021): £264.8m criminal penalty over the Fowler Oldfield account | The Client Engagement | 89% | Detected |
| Mortgage and Property Finance FraudUK Finance, Mortgage Fraud: Good Practice Guidance Note; the FCA's mortgage fraud reporting scheme for lenders and advisers, and… | The Client Account | 84% | Detected |
| Sanctions-Evasion Ownership RestructuringOFSI and FCDO joint guidance on the meaning of ownership and control under UK sanctions, issued following Mints v National Bank… | The Policy Book | 83% | 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.