From Dirty Money to Luxury Goods: Money Laundering in UK Luxury Goods Sectors

This PhD thesis examines money laundering risks within UK luxury goods sectors and identifies ways in which these risks can be significantly reduced. In analysing the UK anti money laundering (AML) regime, the thesis adopts a thematic approach based upon the obligations placed on dealers within the MLRs. In particular, the analysis is conducted in relation to obliged entities, registration, the risk-based approach, Customer Due Diligence (CDD), Suspicious Activity Reporting (SAR), and supervision. The thesis employs a mixed methodology which includes doctrinal and qualitative empirical research methods. The qualitative empirical study gathers insights from dealers with semi-structured interviews.

The study is organised into five parts. The first part provides the theoretical background for the study. This includes consideration of the international and national legislation and policies impacting the UK AML regime. The second part acknowledges money laundering risks in relation to the obligations contained within the MLR and the application of the regime within UK luxury goods sectors. The third part examines compliance challenges faced by dealers in implementing the MLRs. The fourth part considers practices within AML regimes in the US, Cayman Islands, Trinidad and Tobago, Japan, and Canada, which are helpful in evaluating the issues identified within the UK. The final part advances proposals to reduce money laundering risk within UK luxury goods sectors.