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Luxury and money laundering: the blind spot of financial transparency

Organizations seeking to launder money systematically identify safe havens to circumvent controls, particularly when certain environments, such as the banking sector, strengthen their AML-CFT measures.  

Luxury promotes anonymity 

The luxury sector (jewelry, watches, etc.) is one of the sectors where money laundering continues to thrive. It benefits from several advantages that facilitate this crime.  

Small items, but great value! 

Firstly, luxury goods, which can be worth thousands or even hundreds of thousands of euros, allow for anonymity, especially if transactions are carried out through a series of shell companies or front men, making it difficult to attribute an asset to its true owner.  

Easy to transport and conceal 

Unlike financial capital, real estate assets, or yachts, whose transfers are strictly regulated and monitored, luxury goods (watches, jewelry) circulate with remarkable ease, including internationally. They can also be stored without any particular restrictions, in a safe or a simple case. A collector's watch or a diamond weighing a few carats can be worth several hundred thousand euros while still fitting in a pocket. Can we seriously blame a traveler for wearing a high-end watch to tell the time? This is precisely where their appeal lies: these assets concentrate high value in a discreet format, easily transportable from one country to another, and much less likely to arouse suspicion than a visible transfer of funds or a suitcase full of cash. 

A very profitable investment over time 

Finally, as criminal lawyerNicolas Paganelli notes, owning an art collection or a portfolio of rare watches creates the illusion of respectability, concealing the dubious origin of the funds.  Unlike volatile currencies, fine watches (such as certain Rolex or Patek Philippe models), precious stones, and paintings retain or increase their value over time, becoming veritable "parallel currencies." 

Binding legislation... 

Luxury is obviously one of the criteria for AML-CFT compliance. It should be noted that theMonetary and Financial Code, which is subject to anti-money laundering and counter-terrorist financing obligations, applies to persons who trade in works of art and antiques or act as intermediaries, those who accept payments in cash or electronic money in excess of€10,000, as well as"persons whose usual and principal business is trading in precious metals or precious stones, where the value of the transaction or series of linked transactions is equal to or greater than €10,000.

… And dissuasive sanctions! 

Failure to comply with these obligations may result in serious consequences forprofessionals: criminal penalties (up to 5 years' imprisonment and a fine of €375,000), administrative penalties (up to €5 million or 10% of turnover), as well as bans on practicing and damage to reputation. Despite regulatory provisions and the prospect of sanctions, money laundering remains endemic. According to a study published in January 2026 byTransparency International, more than 98% of the proceeds of crime in Europe are neither identified nor recovered, and less than 1% are actually confiscated. Measures for identification, seizure, and confiscation thus remain largely inadequate.   

A lack of information on customers and the origin of funds 

In the art and luxury goods sector, the number of suspicious transaction reports jumped by 218% in 2024, accordingto Tracfin's annual report, and by 237% for precious metals and stones. When suspicious transaction reports are actually submitted by the entities subject to reporting requirements, they are often insufficiently actionable. The reports lack structure, the analysis of the facts giving rise to the suspicion is frequently absent, and supporting documents are not systematically attached. In other words, beyond the volume, it is the very quality of the reports that remains imperfect, limiting the effectiveness of the system. 

Insufficient awareness among luxury industry players 

Despite some progress, luxury professionals are still far from meeting AML-CFT standards of excellence AML-CFT the efforts made remain insufficient: according to experts at theDGCCRF, a significant proportion of manufacturers, distributors, and importers of luxury watches and jewelry, as well as high-end leather goods retailers, are still unaware of the extent of their regulatory obligations. 

Convictions that permanently tarnish one's reputation 

Lack of vigilance now results in heavy penalties. In 2025, following an investigation by the DGCCRF, the NationalSanctionsCommission imposed a €240,000 fine on ajewelry company, along with a 12-month ban on operating. The reasons for this were: a AML-CFT internal AML-CFT system, shortcomings in the identification and updating of customer data, a lack of enhanced vigilance towards foreign or politically exposed customers, and insufficiently controlled cash payments of exceptional amounts, up to €300,000 in a single transaction. 

And the trend continues. In early 2026, the Ministry of Economy sanctioneda Parisian Rolex retailerfor violating anti-money laundering regulations, the second retailer of the brand to be sanctioned in less than three months. In mid-2025, jewelerArijehad already been convicted for repeated cash sales to African dignitaries and businessmen. Beyond the amounts involved, these decisions highlight a strategic reality: when it comes to AML-CFT, financial penalties are only one aspect of the risk. Damage to reputation can prove to be much more costly and long-lasting. 

Regulatory compliance: luxury players at a crossroads 

"Professionals in the sector can no longer be satisfied withsuperficialmeasures. They must have a thorough understanding of AML-CFT rules, or face severe legal, financial, and reputational penalties,"says Lior Delfassy, partner atNovlaw Avocats

To reduce these vulnerabilities, professionals must: 

– Strengthen internal identification procedures by systematically collecting information on customers and Beneficial Owners, using a KYC (Know Your Customer) approach.  

– Implement a documented risk assessment systemtailored to international customers.  

– Train all employees,particularly sales staff and point-of-sale managers, on AML-CFT obligations AML-CFT the detection of red flags, especially cash payments.  

– Collaborate with Tracfin and report suspicious transactionswithout delay. The fact that the number of suspicious activity reports from luxury goods companies is rising sharply is a positive sign of growing awareness, but it is still insufficient given the scale of the problem. 

These requirements become difficult to sustain at scale without specialized technological tools based on augmented intelligence that automate, secure, and document the entire AML-CFT process. 

It is in response to these growing regulatory requirements and major operational challenges thatAP Solutions IOhas designed a suite of innovative technological solutions, combining business expertise and augmented intelligence. 

  • AP Scan is a turnkey solution that automates the entire detection process and simplifies alert management, while boosting the efficiency of compliance teams. 
  • AP Scoring, an augmented intelligence engine, uses powerful algorithms to analyze customer data and financial transactions in order to accurately assess and score their level of risk. 
  • AP Monitoring enables you to identify, monitor, and report suspicious activity in real time using an advanced behavioral analysis engine. 
  • AP Filter ensures the detection of international sanctions and the identification of countries and currencies subject to embargo regimes. 

By offering a comprehensive, scalable, and automated approach to compliance,AP Solutions IO provides institutions with long-term support in managing their risks, protecting their reputation, and securing their operations in an ever-changing regulatory environment. 

Aurélien Zachayus
Co-Founder – CEO at AP Solutions IO

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