Recognising the schemes

Authorities and the Observatory have catalogued the most common money laundering schemes through art. They rely on a small number of mechanisms that operators can learn to recognise.
This page presents six typologies, with, for each, its principle, its warning signs and the recommended reaction.
It draws on anonymised real cases from the reports received by OIMAP between 2020 and 2024.
Money laundering typologies in the art market in figures
Source: OIMAP Legal Affairs Department.
Inflated prices and fictitious sales
In the first scheme, a work is bought at a price far above its value by an accomplice, the excess representing money to be laundered. The seller, who receives a high price, can then justify funds that appear lawful. In the second, the sale is purely fictitious: the work does not move, but a contract and a payment justify it.
The warning signs are a large gap from market prices, rapid resales to the same buyer or sales between related parties. Independent appraisal and comparison with the Observatory's price databases help to detect them.



Free ports, shell companies and split payments
Free ports make it possible to store works with suspension of duties, sometimes for years. Several sales can take place there without the work moving, which complicates tracking. Shell companies are used to hide the real beneficiary of a purchase or sale.
Splitting consists of dividing a payment into several settlements below the vigilance threshold. Operators must look at the sum of linked payments rather than each one in isolation.
Learning from cases
The study of real cases is the best way to train teams. OIMAP publishes about ten anonymised teaching cases each year, with the course of the investigation and the lessons learned. They are used in the Academy's training and in the programmes of several universities.
Each case ends with a series of questions the operator can answer to test their own vigilance: which signal would I have spotted? At what point would I have asked questions?
Six schemes
| Scheme | Principle | Warning sign |
|---|---|---|
| Inflated price | Buy very dear to justify a gain | Gap from market prices |
| Fictitious sale | Make it look like a sale | No physical movement of the work |
| Free port | Store with suspension of duties | Changes of ownership without movement |
| Shell company | Hide the beneficiary | Opaque structure, high-risk jurisdiction |
| Fractionalisation | Avoid the vigilance threshold | Repeated payments just below the threshold |
| Digital token | Move funds through tokens | Looped resale between linked accounts |
Landmarks
- First reports
Creation of the unit.
- Guide to typologies
First publication.
- Digital tokens
New typology.
- Network dismantled
Five States cooperate.
A signal is not proof
Atypical or suspicious transaction

Atypical
Out of the ordinary- To be examined
- May have an explanation
- Justification requested
First step.

Suspicious
Explanation not convincing- Well-founded suspicion
- Reporting mandatory
- No information to the client
Second step.



Reacting to an atypical transaction
- Spot
Identify the signal.
- Question
Ask for explanations.
- Check
Check the answers.
- Decide
Conclude, refuse or report.
- Document
Record the steps taken.
Questions to ask yourself
A financial analyst

« No scheme is perfect. There is always a moment when someone could have asked a simple question. »
Vocabulary of typologies
- Overvaluation
- Price above real value.
- Related party
- Person with a link to another party.
- Shell company
- Entity with no real activity.
- Fractionalisation
- Splitting of a payment.
Frequently asked questions
Useful documents
Contacts

See how to report
Image credits (16)
- American Red Cross War Council Medal (obverse), Daniel Chester French (1920) — Cleveland Museum of Art, CC0 1.0
- Dr. James Stuart; Mary Campbell Stuart, Gilbert Stuart (c. 1815) — Cleveland Museum of Art, CC0 1.0
- Solidus of Justinian I (obverse) (c. 545–565) — Cleveland Museum of Art, CC0 1.0
- At the Market, Camille Pissarro (late 1800s) — Cleveland Museum of Art, CC0 1.0
- Coin of Demetrios, I (reverse) (200–190 BCE) — Cleveland Museum of Art, CC0 1.0
- The Calumny of Apelles, Giorgio Ghisi (1560) — Cleveland Museum of Art, CC0 1.0
- Tetradrachm: Owl, Crescent Moon, Olive Branch (reverse) (480–449 BCE) — Cleveland Museum of Art, CC0 1.0
- Views: The Market on the Molo, Antonio Canaletto (1735–1746) — Cleveland Museum of Art, CC0 1.0
- Leopard d'Or of Edward III of England (1327–1377) — 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
- Coin of Eukratides I (170–145 BCE) — Cleveland Museum of Art, CC0 1.0
- The Doge's Palace, Venice, Richard Parkes Bonington (1826) — Cleveland Museum of Art, CC0 1.0
- Solidus with Busts of Constans II and Constantine IV (obverse) (659–661) — Cleveland Museum of Art, CC0 1.0
- Vanity Case (Nécessaire) (c. 1760) — Cleveland Museum of Art, CC0 1.0
- Courtyard, Alhambra, Charles Clifford (1857–58) — 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
Cleveland Museum of Art · CC0 1.0
Anti-money launderingThe art market and money laundering: typologies, vigilance obligations, reporting and sanctions.›
Reporting suspicious transactionsHow, when and to whom to report a suspicious transaction: procedure, content of the report, protection of the reporter and follow-up.›
Digital market regulationCrypto-assets, tokens backed by works and online platforms: the legal framework of the digital art market.›