Dealer in Goods of Great Value

Recognizing unusual transactions

The group of dealers in high-value goods includes all service providers who act professionally or commercially in or mediate in the purchase and sale of:

1. real estate,
2. vehicles,
3. ships,
4. aircraft,
5. works of art,
6. art and antiques,
7. the rights to which the aforementioned goods are subject,
8. precious metals, precious stones, and jewelry;

As a dealer of high-value goods, you are familiar with the practices within your line of business. Whether a transaction is considered unusual depends largely on your professional judgment. Your judgment is consistent with what is considered unusual within your profession. In addition to your judgment, there are situations that are unusual by nature and should therefore be reported.

If a situation arises as described in the examples below (not exhaustive), this is a reason to further examine whether the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses. It is not necessary to determine with certainty that the above-mentioned crimes have been committed. You merely need to have an assumption that the transaction can be related to one of these crimes.
If you believe that the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses, you are required to report this under the subjective indicator.

Red flags – Dealer in high-value goods – General

• The client purchases expensive goods without having any interest in the quality, specific features of those goods
• The client shows no interest in possible defects of the items or shows little interest in the possible costs of repairing them
• The client is willing to buy expensive goods without an attempt to negotiate the price or without asking for a discount
• The client’s expenses are excessive and do not correspond with the expenditure pattern of a person with a similar occupation or income as that of the client
• The clients purchases goods for himself and/or in the name of others more often than is usual for this kind of customer

Red flags – Jeweler

• The client buys expensive jewelry without having any interest in the kind of jewelry that is bought and / or without paying specific attention when selecting the jewelry
• The client buys expensive jewelry that does not correspond to the client’s profile considering his profession or income
• The client attempts to resell the newly bought jewelry at a lower price without providing a valid reason
• The client is willing to buy expensive jewelry without attempting to negotiate the price or without asking for a discount
• The client is willing to sell jewelry for a price which is lower than the market value

Typologies: