Q: Who is concerned by AML/CFT?

You are auctioneers: LCB-FT concerns you directly, and did so 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 <a href="%E2%80%9Chttps://www.eunomart.com/post/ce-qu-il-faut-retenir%E2%80%9D">European LCB-FT Directive</a> 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's 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's not a textbook case. You have a duty of care, but your obligation is one of due care. This means that you must undertake to use all necessary means to fulfill this obligation of vigilance. [<img src="https://storage.crisp.chat/users/helpdesk/website/-/e/b/b/f/ebbfa5cf1bf20000/23e0f2bc-a316-4ae1-b944-259881_10ppzpi.jpg" alt="" />](https://eunomart.intercom-attachments-1.com/i/o/1123016509/504a7fd926fccf4073cbf62b/827b39_61dbb9db734e455197261f482c8df54c~mv2.jpg?expires=1772555400&amp;signature=2ba8d1a605bf056b13299d813876748542836a0b54e8b890805489c1e5a9d6c3&amp;req=dSElFcl%2Fm4RfUPMW1HO4zTSuBRou686361WzltCx0bERFRoV3A

Question 1

A look back at the Customs 2023 AML self-assessment campaign

Accepted Answer

Between June and October 2023, Customs conducted a self-assessment campaign among the professionals under its supervision, aimed at achieving two main objectives:

For professionals: to assess their level of knowledge of the regulations and the compliance of their LCB-FT system on a declarative basis.
For customs: to obtain information on the sector's general understanding of the regulations, and to gain a better understanding of the market (frequency of transactions over €10,000, average size of players, etc.).

The campaign has shown that the industry is well aware of the risks, and that significant progress has been made in raising awareness.

However, significant gaps remain in the implementation of obligations:

Organizational: Fewer than half of respondents have formalized their risk classification or taken appropriate training.
Operational: Weaknesses in identity verification, knowledge of business relationships, and monitoring of operations, as well as in compliance with international sanctions and asset freezes.

These results underline the progress made, while highlighting areas requiring improvement.

A new self-assessment campaign will be carried out in 2024 with professionals who did not respond in 2023!

To find out more: www.douane.gouv.fr

Question 2

Monaco added to the GAFi grey list

Accepted Answer

On Friday June 28, 2024, the Financial Action Task Force (FATF) placed Monaco and Venezuela on its “enhanced surveillance” gray list. In a press release, the GAFi specified that these two territories required enhanced surveillance.

Although Monaco has made significant progress, GAFi stressed the importance of improving the fight against tax fraud, offshore money laundering and the application of dissuasive sanctions. Monaco had already been called to account in January 2023 for improvements in these areas.

What is the GAFi?

The Financial Action Task Force (FATF) is an intergovernmental organization created in 1989 by the G7.

Its main objective is to develop and promote national and international policies to combat money laundering, terrorist financing and other threats to the integrity of the international financial system.

The FATF sets standards and monitors their effective implementation by member countries, assessing their regulatory frameworks and providing recommendations to improve their prevention and enforcement systems.

And what is the “grey list”?

The Financial Action Task Force's (FATF) “grey list” comprises jurisdictions that have strategic shortcomings in the fight against money laundering and terrorist financing, but have committed to addressing these shortcomings.

These countries are placed under increased scrutiny and must implement action plans to improve their regulatory and operational frameworks to compl

Question 3

What are the main stages in your compliance process?

Accepted Answer

Compliance is an essential pillar in guaranteeing not only legality, but also the safety of operations.

At Eunomart, we understand that this process can seem daunting. As the famous saying goes, “Rome wasn't built in a day”. It's crucial to start somewhere and progress step by step.

To help you along the way, we've put together a step-by-step guide to achieving full compliance!

1. Understand and assess your global business

The first step is to draw up a risk map. This process, to be carried out once a year, helps to identify and highlight potentially risky areas in your business. Next, it's important to establish a risk classification and determine the appropriate levels of vigilance for each category. Finally, an internal protocol should be drawn up to document all the actions and procedures implemented within your facility.

2. Assessing the risks associated with your objects and vendors

Next, turn your attention to assessing the risks associated with your objects and vendors. This includes identifying risk factors concerning the provenance of works or the identity of vendors. Rigorous analysis at this level is crucial to avoid any involvement in fraudulent or illegal activities.

3. Analyze your buyers' risks

The next step is to analyze the risks associated with your buying customers. For every customer making purchases over €10,000, whether in a single transaction or cumulatively, you need to compile a risk assessment

Question 4

Subscription and billing

Accepted Answer

How do I change my billing email?

To change your billing email/address, go to Company settings (top right-hand corner of the screen) > Invoices and payments > Modify my billing information. You'll be able to update your billing information.

How can I find and download my invoices?

To download Eunomart invoices, go to Company settings (top right of screen) > Invoices and payments > Change my billing information.

Can I cancel my subscription at any time?

We renew your annual and monthly subscriptions automatically. But please note that our subscriptions are non-binding: you can terminate them at any time, without notice, by logging on to your account or sending an e-mail to contact@eunomart.com, right up to the renewal date. You will then be able to use the software until the end of the current paid period.

For example: if you have taken out an annual subscription and wish to cancel it after 6 months, you will benefit from the tool for another 6 months, with no renewal at the end.

What's the best price for me?

To find out which rate is best for you, we recommend that you contact our team by e-mail at contact@eunomart.com. In fact, invoicing evolves according to your sales volume. We'll t

Question 5

What are the penalties?

Accepted Answer

The Commission Nationale des Sanctions (National Sanctions Commission ) is responsible for dealing with any breaches of the law observed by customs services during inspections, and imposes the sanctions provided for in the Monetary and Financial Code.

This is indeed a sensitive subject, but it's important for everyone to be aware of the risks to which they are exposing themselves by choosing to apply the anti-money laundering directives only partially, or not at all.

In accordance with Article L. 561-40 of the CMF, the Commission Nationale des Sanctions may impose **t

Question 6

Who is concerned by AML/CFT?

Accepted Answer

You are auctioneers: LCB-FT concerns you directly, and did so 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 LCB-FT 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's 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's not a textbook case.

You have a duty of care, but your obligation is one of due care. This means that you must undertake to use all necessary means to fulfill this obligation of vigilance.

[](https://eunomart.intercom-attachments-1.com/i/o/1123016509/504a7fd926fccf4073cbf62b/827b39_61dbb9db734e455197261f482c8df54c~mv2.jpg?expires=1772555400&signature=2ba8d1a605bf056b13299d813876748542836a0b54e8b890805489c1e5a9d6c3&req=dSElFcl%2Fm4RfUPMW1HO4zTSuBRou686361WzltCx0bERFRoV3A

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