The control gap we probe
Due diligence concentrates on the buyer and rarely on the arrangement. Nobody reconciles rent credits against occupancy, and a valuation resting entirely on expert opinion is treated as a fact rather than an opinion.
All sectors
Sector assessment
Property, Art and High-Value Dealers
6 laundering methods apply to this sector. 3 are rarely covered in standard AML training. The sector assessment uses 5 cases.
Property and high-value goods hold value, change hands easily, and in the case of art and antiquities carry no ownership registry at all.
Start The Private Client File — 8 minNo account required · Full debrief at the end
- Typologies for you
- 6
- Assessed
- 6
- Rarely trained
- 3
- Aimed at
- MLRO, Compliance Manager, Practice Risk
Supervisory context
The 2019 amendments to the Money Laundering Regulations brought art market participants and letting agents into scope, and the Register of Overseas Entities put beneficial ownership of UK property on the record. HMRC supervises the sector and publishes enforcement against unregistered businesses.
Who this is for
Estate agency is in scope in full. Letting agency is in scope where the rent reaches the threshold set in the 2019 amendments. Art market participants are in scope on transactions at or above 10,000 euros, and high value dealers on cash at or above the same figure. If you are in one of the last three, the threshold is the first thing to check, because being under it is a position you have to be able to evidence rather than assume.
The Property and Art Assessment
Not one case. Every case that exercises a typology on your list is part of your mark, weighted by how much of your exposure it carries. The weights are derived from the register rather than chosen, so adding a case re-derives them instead of leaving the old ones wrong.
- Cases in your assessment
- 5
- Time to sit all of them
- 40 min
- Typologies covered
- 6
- Left uncovered
- 0
| Case | Your typologies | Share of your mark |
|---|---|---|
| The Private Client Filewritten for your desk | 3 | 44% |
| The Client Account | 1 | 14% |
| The Funnel Account | 1 | 14% |
| The Goods Chain | 1 | 14% |
| The Relationship Review | 1 | 14% |
What you get for the price
£99one payment, 12 months, nothing renews
- All 5 cases in your sector assessment, about 40 minutes, plus every other case on the site
- Your mark for the Property and Art Assessment, and a full debrief on every case naming each finding and its source
- A certificate recording exact CPD hours, publicly verifiable
- Re-sit any case as often as you like for 12 months
£750pilot, up to 25 people, invoiced
- Your whole team sits the Property and Art Assessment, not a single case
- A gap report naming which of your 6 typologies the team detected and which they missed, with detection rates
- Every participant gets their own full debrief
- Deducted from a licence if you take one within 90 days
The 6 typologies that apply to this sector
Drawn from the full register and filtered to this sector. Each entry states what the typology looks like inside your own systems, and names the source it came from. 6 of the 6 are currently exercised by an assessment case; the rest are documented here and not yet built into one.
Placement and collection1
Human Trafficking and Modern Slavery ProceedsRarely covered in training
In the assessment
Victims are exploited through labour or sexual services, and the proceeds are placed through cash-intensive front businesses or through the victims' own accounts, which the controller operates.
What the analyst sees
Funnel accounts taking cash deposits below the reporting threshold in one location and withdrawn immediately in another; multiple unrelated accountholders sharing an address, device or telephone number; wage payments returned to the employer shortly after credit; customers who never attend alone and whose account is operated by a third party.
Corporate and identity1
Investment Migration and Residence Schemes
In the assessment
Residence or citizenship is obtained through qualifying investment, converting funds of uncertain origin into a residency status that subsequently anchors banking relationships and asset holdings.
What the analyst sees
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.
Assets and stores of value4
Art and Antiquities: self-dealing at auctionRarely covered in training
In the assessment
An object of unverifiable age is commissioned or acquired, given a provenance story, consigned through a trust and bought back by its own beneficial owner through competing bidders, converting funds into an auction settlement.
What the analyst sees
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.
Real Estate: engineered foreclosure and retained controlRarely covered in training
In the assessment
Property is nominally lost to a creditor while beneficial ownership never changes, or is held through a dissolved foreign entity that remains the registered owner.
What the analyst sees
Repossession followed by continued occupation or management by the former owner, debt routed through a professional intermediary, and funds flowing back to the supposedly dispossessed party.
Fabricated Rental Income and Ghost Tenants
In the assessment
A property portfolio reports rent from tenants who do not exist, giving illicit cash a documented income stream and a tax history.
What the analyst sees
Rent credits inconsistent with occupancy or utility data, tenants who never pay late, and payments originating from accounts connected to the landlord.
High-Value Portable Goods
In the assessment
Watches, vehicles, gemstones and collectables convert cash into portable value that resells readily and carries no ownership registry, moving across borders as personal property.
What the analyst sees
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.
Sit your own sector's case before you commit a team to it
The Private Client File carries 3 of the 6 typologies above and 44 per cent of your mark. Full debrief, no account, no card.
Start The Private Client FileRun the full Property and Art benchmark across up to 25 people for £750.
No integration · No customer data · Confidential cohort available
The weekly case
One documented case each week. One decision. The answer and the source afterwards.