You are auditors: the LCB-FT concerns you directly, even before this latest European Directive of 2020. You are at the heart of economic transactions which, sometimes, even often, have high added value and which today may represent a risk of money laundering or terrorist financing.
You are a gallery owner or an antique dealer: your art market sector has been identified since the 2001 European AML/CFT Directive as potentially being used by your customers to launder funds or finance terrorism. In this respect, you are economic players who can detect suspicious activity or transactions, in the same way as auctioneers.
Even if it is hard to feel concerned by the subject and to imagine that one of your customers and/or works could be involved in this kind of scheme, it is not a textbook case.
You have an obligation to exercise due care, but your obligation is an obligation of means. This means that you must undertake to use all necessary means to fulfil this obligation of vigilance.
