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A virtual space with real regulation

How art world leaders can embrace new money laundering regulations and create a think risk culture

Money Laundering Reporting Officers in the art world face stiff criminal punishments if they contravene new regulations © Thomas Dumortier Why would anyone be a compliance director when the risk of financial and criminal exposure is so high? As the founding global compliance director of Sotheby’s in 1998 and having watched the explosion of international anti-money laundering regulations recently, I have often wondered this. From personal experience, it is a virtual certainty that your average Money Laundering Reporting Officer (MLRO) is not paid enough to make the risks worth taking. But while the EU’s 2019 5th Directive on Money Laundering (5AMLD) genuinely improves the situation for MLROs in the art market by sharing the risks more broadly, this is not such good news for “senior management”.

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