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.
Sector assessment
18 laundering methods apply to this sector. 10 are rarely covered in standard AML training. The sector assessment uses 14 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.
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.
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.
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.
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.
| Case | Your typologies | Share of your mark |
|---|---|---|
| The Private Client Filewritten for your desk | 4 | 13% |
| The Relationship Review | 6 | 22% |
| The Client Account | 5 | 17% |
| The Policy Book | 3 | 10% |
| The Client Engagement | 2 | 7% |
| The Goods Chain | 2 | 7% |
| The Collection Network | 1 | 3% |
| The Disclosure | 1 | 3% |
| The Exchange Desk | 1 | 3% |
| The Funnel Account | 1 | 3% |
| The Onboarding Interview | 1 | 3% |
| The Securities Book | 1 | 3% |
| The Trade Corridor | 1 | 3% |
| The Verification Desk | 1 | 3% |
£99one payment, 12 months, nothing renews
£750pilot, up to 25 people, invoiced
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. 18 of the 18 are currently exercised by an assessment case; the rest are documented here and not yet built into one.
A genuine cash trading business banks criminal cash alongside its own takings, using the trade's plausible cash profile as cover.
Deposit volumes far exceeding what the trade supports, physical tells at the counter, and transaction monitoring that misclassifies the deposit type.
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.
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.
Physical currency is consolidated and moved across borders by courier, vehicle or freight, avoiding the banking system entirely until it reaches a jurisdiction where placement is easier.
The banking exposure sits either side of the movement: aggregation of cash before departure through connected accounts and businesses, and placement afterwards in the destination jurisdiction with no corresponding trade.
Deceased individuals are recorded as directors, officers and shareholders, and accounts opened by the living are run on after death. There is no accomplice who can be pressured, because the nominal principal is dead.
An account in good standing whose signatory died in a jurisdiction the firm does not search, filings continuing for a director with no verifiable life, and mandates never refreshed because the account never triggered a review.
A company is dissolved or struck off the register yet continues to bank, invoice and transact, because registry status is checked at onboarding and never again.
An established account whose entity no longer exists at the registry. Detectable only by re-verifying incorporation status across the existing book, which is a batch job most firms have never run.
Layered holding structures across free-zone and offshore jurisdictions terminate in a corporate nominee, so the declared beneficial owner is asserted rather than evidenced.
A structure chart that never evidences control, a nominee shareholder defeating verification, and a customer who offers further documents instead of an answer.
Statements, identity documents and supporting evidence are generated rather than obtained, and are internally consistent in ways genuine documents are not.
Statements with no fees or charges across months, running balances consistent to the penny, logos at incorrect aspect ratio, institution codes in the wrong format, identity photographs internally inconsistent or inconsistent with stated age, third-party webcam plugins during liveness checks.
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.
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.
Professional laundering networks settle obligations by offsetting: cash is delivered to a criminal group in one country while an equivalent sum is credited in another, with no cross-border transfer. Purchasing agents buy luxury goods on cards and settle the balances with criminal cash.
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.
Cash buys gold, gold crosses borders as scrap, jewellery or dore, and refining resets its origin. Bars are also used to move value physically, sometimes with counterfeit cores.
Bullion dealer and refiner accounts with volumes inconsistent with declared sourcing, and national export statistics exceeding any domestic mining or refining capacity.
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.
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.
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.
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.
A property portfolio reports rent from tenants who do not exist, giving illicit cash a documented income stream and a tax history.
Rent credits inconsistent with occupancy or utility data, tenants who never pay late, and payments originating from accounts connected to the landlord.
Watches, vehicles, gemstones and collectables convert cash into portable value that resells readily and carries no ownership registry, moving across borders as personal property.
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.
Borrowing is obtained on fabricated income, undisclosed deposits of criminal origin, or inflated valuations, and the loan both launders the deposit and generates a legitimate ownership record.
Deposits gifted by parties with no evidenced means, income documentation that cannot be corroborated with the employer or HMRC, valuations materially above comparable sales, and early full repayment shortly after completion.
Assets pass through the administration of a deceased person's estate, where the party whose funds they were is beyond enquiry. Due diligence is performed on executors and beneficiaries; the deceased is not checked, and the estate's assets move through a firm's client account before distribution.
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.
Criminal funds are placed offshore and then lent back to the launderer, so the money returns as borrowing, complete with a repayment schedule, an interest deduction and an apparently arm's-length lender.
Borrowing from an offshore entity with no lending business, security or guarantees provided by parties connected to the borrower, interest paid to a jurisdiction unrelated to the transaction, and loans that are never enforced when they fall into arrears.
Ownership is diluted below control thresholds or transferred to non-designated relatives and managers after designation, leaving effective control unchanged.
Ownership changes closely following a designation date, incoming owners with no commercial history, and unchanged management across the restructuring.
The Private Client File carries 4 of the 18 typologies above and 13 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.
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One documented case each week. One decision. The answer and the source afterwards.