Cleveland Museum of Art · CC0 1.0Pages in this section
Money laundering typologies in the art marketThe most common money laundering schemes through art: inflated prices, fictitious sales, free ports, intermediaries and digital tokens.›
Reporting suspicious transactionsHow, when and to whom to report a suspicious transaction: procedure, content of the report, protection of the reporter and follow-up.›
Money laundering sanctions in the art marketThe penalties and measures incurred by operators and persons involved in money laundering: criminal, administrative and professional sanctions.›
A market attractive to dubious money
The high value of works, the ease of transporting them and the discretion of some transactions make the art market attractive for money laundering. OIMAP Member States have therefore built vigilance obligations into the 2019 directives.
They require operators to identify their clients, understand the origin of funds, spot atypical transactions and report them. They also protect operators: a vigilant operator does not risk being an unwitting accomplice.
This section presents the typologies, the reporting procedure and the sanctions.
Anti-money laundering in figures
Source: OIMAP Legal Affairs Department.
The three pages of the section
Operators' obligations
Operators must identify their clients and beneficial owners, understand the purpose and nature of the transaction, verify the origin of funds when the amount exceeds the thresholds, monitor atypical transactions and report suspicions to the competent authority.
These obligations are proportionate: an operator selling prints at €300 is not bound by the same procedures as an auction house knocking down works for several million.
Why the art market is vulnerable
Several factors explain this vulnerability: prices that are not based on a stock-market quotation but on a subjective assessment, making an inflated price hard to detect; the mobility of objects, which allows them to be moved discreetly; the use of intermediaries and shell companies.
Free ports and long-term storage also raise questions: a work can change owner there several times without ever crossing a border or appearing in a sales declaration.
International cooperation
Money laundering knows no borders; detecting it relies on cooperation. OIMAP exchanges information with the financial intelligence units of Member States, with INTERPOL and with the World Customs Organization. It takes part in joint exercises to detect schemes.
In 2024, cooperation of this kind made it possible to identify a network using fictitious online sales to move funds. The investigation, carried out in five States, led to the seizure of more than twelve million euros.
Identification thresholds
| Situation | Threshold | Measure |
|---|---|---|
| Physical sale | €10,000 | Identification and origin of funds |
| Online sale | €1,000 | Identification and enhanced verification |
| Cash payment | €3,000 | Prohibited or tightly regulated |
| Transaction with a high-risk State | From the first euro | Enhanced vigilance |
Landmarks
- Directive 2019-03
Integration of vigilance.
- Typologies
OIMAP's first guide.
- Digital regime
Threshold of €1,000.
- 1,940 reports
Increase of 38%.
A vigilant operator is a protected operator
Basic or enhanced vigilance
Basic
Ordinary transaction- Identification
- Origin of funds below threshold
- Routine monitoring
General case.
Enhanced
High risk- Justification of wealth
- Management authorisation
- Increased monitoring
Exposed persons, high-risk States.
Setting up a system
- Assess
Map the risks.
- Organise
Appoint a focal person.
- Train
Train the teams.
- Monitor
Monitor the transactions.
- Report
Raise the alarm in case of suspicion.
Common warning signs
A financial magistrate
« In the cases I handle, the work of art is rarely the end in itself. It is a vehicle for moving money from one point to another. »
Vocabulary of money laundering
- Money laundering
- Concealment of the illicit origin of funds.
- Beneficial owner
- Person who actually controls a company.
- Politically exposed person
- Person holding an important public function.
- Free port
- Customs storage zone.
Frequently asked questions
Are private individuals concerned?
Indirectly, through the operators they deal with.
Who receives the reports?
The national authority and OIMAP.
Where can I find examples of schemes?
In the typologies.
What sanctions?
See Sanctions.
Useful documents
Contacts
Related pages
Money laundering typologies in the art marketThe most common money laundering schemes through art: inflated prices, fictitious sales, free ports, intermediaries and digital tokens.›
Reporting suspicious transactionsHow, when and to whom to report a suspicious transaction: procedure, content of the report, protection of the reporter and follow-up.›
Money laundering sanctions in the art marketThe penalties and measures incurred by operators and persons involved in money laundering: criminal, administrative and professional sanctions.›
Due diligenceThe checks every operator must carry out before buying, selling or presenting a work: guide, checklists and templates.›
Discover the typologies
Image credits (23)
- Solidus with Busts of Constans II and Constantine IV (obverse) (659–661) — Cleveland Museum of Art, CC0 1.0
- American Red Cross War Council Medal (obverse), Daniel Chester French (1920) — Cleveland Museum of Art, CC0 1.0
- Coin of Eukratides I (170–145 BCE) — Cleveland Museum of Art, CC0 1.0
- Portrait of John VIII Palaeologus, Emperor of Constantinople, 1424-1428 (obverse), Pisanello (c. 1438–1439) — Cleveland Museum of Art, CC0 1.0
- The Antechamber of the Palace of Justice, Paris, Charles Meryon (1855) — Cleveland Museum of Art, CC0 1.0
- Portrait of Pope Paul II Barbo (obverse) and (reverse), Cristoforo di Geremia (c. 1468) — Cleveland Museum of Art, CC0 1.0
- At the Market, Camille Pissarro (late 1800s) — Cleveland Museum of Art, CC0 1.0
- Solidus of Justinian I (reverse) (545–565) — Cleveland Museum of Art, CC0 1.0
- Sketches in Belgium and Germany, Volume I: Hall of Justice of the Magistrates du Franc, Bruges, Louis Haghe (1840) — Cleveland Museum of Art, CC0 1.0
- American Red Cross War Council Medal (reverse), Daniel Chester French (1920) — Cleveland Museum of Art, CC0 1.0
- Views: The Market on the Molo, Antonio Canaletto (1735–1746) — Cleveland Museum of Art, CC0 1.0
- Guinea: Anne (obverse); Shields and rose (reverse) (1703) — Cleveland Museum of Art, CC0 1.0
- The Judgment of Solomon and Esther before Ahasuerus (pair), Dirk Vellert (c. 1530) — Cleveland Museum of Art, CC0 1.0
- Stater: BODVOC on plain field (obverse); Horse, Wheel, and Crescent (reverse) (10 BCE–20 CE) — Cleveland Museum of Art, CC0 1.0
- The Auction House: The Town Crier, Honoré Daumier (1864, printed 1920) — Cleveland Museum of Art, CC0 1.0
- Tetradrachm: Head of Antiochos VIII (obverse); Zeus Ouranios (reverse) (112–110 BCE) — Cleveland Museum of Art, CC0 1.0
- Dr. James Stuart; Mary Campbell Stuart, Gilbert Stuart (c. 1815) — Cleveland Museum of Art, CC0 1.0
- Egypt and Nubia, Volume I: The Great Temple of Aboo-Simble, Nubia, Louis Haghe (1846) — Cleveland Museum of Art, CC0 1.0
- Solidus of Justinian I (obverse) (c. 545–565) — Cleveland Museum of Art, CC0 1.0
- The Calumny of Apelles, Giorgio Ghisi (1560) — Cleveland Museum of Art, CC0 1.0
- Provincial Coin: Head of Antoninus Pius (obverse); Apollo Sauroktonos (reverse) (138–161 CE) — Cleveland Museum of Art, CC0 1.0
- Mercury (Budha), from a Mandi Astrology Series, Sanju (c. 1810) — Cleveland Museum of Art, CC0 1.0
- Medal Depicting Gian Lorenzo Bernini (1598-1680) from the Illustrious Men of the Kingdom of the Two Sicilies (obverse), V. Catenacci (1830–34) — Cleveland Museum of Art, CC0 1.0