Welcome to Codex Pro Arte.
Personal Journey Meets Professional Purpose
Welcome to the first post in Codex Pro Arte, the blog series (frequency to be determined) from me, Alvinder/Alvin/Al - contract at your pleasure. I will be bringing together art and anti‑money laundering (AML) expertise in a simple and interesting way - passion meets profession indeed. A sporadic thought I’m sure many who’ve abandoned the pursuit of an art ponder, me included, is the wish of having had pursued their creative leanings - I often have that thought and I always think there’s still time. But time ticks and takes from us, while giving pause for life and thought, though of itself it usually gives back nought. I’m not sure the time will ever be right.
I would be delighted to share a bit of my personal journey, and how a foundation in art and design evolved into a lifelong love for art, that was never really given the time it deserved. So now, I attempt to give myself a second chance - a moment that feels not only emotionally resonant, but logically compelling, to explore that passion through the prism of compliance. A bit dull you might think, me too, but maybe not, not if it works.
I began my failure as an artist and designer at the age of 16, at A-level, studying art and then continued to somewhat succeed in the area of multidisciplinary design (specifically fashion and multimedia), that then was the end of my training and career as an artist and designer. Prior to this things had looked pretty good, I used early computers to make art (anyone know what a Commodore 64 is?), when I was 9 years old, I drew images of cartoon characters and made stickers of them which I sold in the playground. I always did well and enjoyed art, gaining an A grade at GCSE - my final projects were wire and clay sculpture! And that, as they say, was that - I peaked far too early and then life gave me too many options and not enough sense to take the right ones. Post age 19, I became a hobbyist photographer and visiter of galleries- that was it for me. I appreciate all the opportunities I’ve had, more so knowing the nature of this world. Art has always brought me joy, it is a connector of times and people, teller of stories and conduit of escape - it is for everyone whether they know it or not.
Recently, I’ve taken my passion one step further: I’ve started acquiring modest pieces of original art rather than prints and poster. These early purchases - humble but meaningful - felt both like overspend and inevitability. It gave rise, slowly, to a want to further understand artistic expression and the various facets of art as an asset. The aspect of the latter that is especially interesting, is art through the lens of crime. Over the years I had seen numerous fascinating documentaries related to looting, heists and counterfeits - and then the AMP rules came out and I began pondering and wondering. But that was all I did, I had plenty of work with banks but now that blessed time has come to an end, and it is through both want and need that I am embarking on this new phase. I just hope I am barking up the right tree.
That intersection of crime, art and compliance is where Codex Pro Arte was born, a rather unimaginative use of Latin meaning codex for art but it works for me.
While I didn’t take this photo, I did visit the Van Gogh Art Lighting Experience in Paris, that was in 2019 I think - cool but overpriced, as the best things usually are...
Why Art Compliance Matters.
The art market, by its very nature, has long attracted regulatory scrutiny. Its subjective valuations, discreet transactions, anonymous intermediaries, and use of freeports make it vulnerable to abuses such as money laundering, fraud, and other predicate crimes, including embezzlement, corruption, trade-based money laundering, and sanctions evasion. The Financial Action Task Force (FATF) has specifically flagged art and antiquities as high‑risk sectors in its 2023 guidance paper - a long but interesting read.
In the European Union, since 2020, the Fifth Anti‑Money Laundering Directive (5AMLD) came to explicitly encompass art auction houses, galleries, and dealers. In the UK, Money Laundering Regulations 2017 (as amended 2020) require registration and customer due diligence for art professionals dealing in works above €10,000 (let’s say £8650 but I’d opt for £8500 to be safe in terms of application), and failure to comply has already resulted in fines and enforcement actions - that one chap was just sent to jail...
Meanwhile, in the United States, the Anti‑Money Laundering Act of 2020 extended AML obligations to antiquities dealers—but the broader art market remains largely unregulated, despite repeated proposals and recognized risks. Provocatively, some estimates place illicit flows through the art market in the billions annually and it wouldn’t surprise me. Nor would eventual adoption of these rules around the world, the multi-millionaires and billionaires will not be please. However, we are here to help, and we must frame these regulations for they are. No, not a massive pain in our backsides, but a even more massive pain in the backsides of criminals attempting to use beauty as a beastly means to launder money. Doing the right thing isn’t always easy, but we hope to make it easier.
What if you sell art to a person who is violent criminal or corrupt leader of a poor country? Would you be happy to take that money? Ignorance is easy, action is less so. But as cultured folk we must do the right thing, even if it is a pain in seating cushions.
This is why the market for what you love must be regulated, these worlds must coexist intelligently - and Codex Compliance aims to serve both.
The Gun Salute" (also known as "Le coup de canon" or "The Cannon Shot") by Willem van de Velde the Younger. While you may be up in arms, we also must take up arms.
What to Expect from Codex Pro Arte
I’ll will bring my waffling, rambling, word-smudgery into the aml x art world, and share various things (hopefully whilst gaining some custom) including enforcement actions, interesting typologies and stories, my ideas about this space, and might even find time to indulge in sharing my favourite art and artists - from Aivazovsky to Yukhnovich - Ivan and Flora respectively, are two very talented, different and wonderfully named individuals.
Obviously, there might be some art market AML and compliance analysis with the odd mention of FATF principles, CDD/EDD, risk assessment, predicate crime detection, sanctions law, and record‑keeping best practices. All that fun stuff. I also hope to continue sharing practical guidance for art market participants (galleries, dealers, advisors, collectors) on navigating KYC, suspicion indicators, and reporting obligations.
As some of this is new to me I will also likely be exploring, sharing some forward‑looking commentary on emerging challenges, including NFTs, freeports, high‑value private sales, and cross‑border regulatory divergence. I look forward to the learning journey.
I will attempt to share clearly and simply, but if you want to get ahead of the curve then check out the resources page which has an AML 101 guide and Art Market AML glossary available for download.
Thanks for stopping by.
Alvin
To check out some of my old blabberings, on the old Codex Compliance site that has been decommissioned - head here;
https://rottenandco.wixsite.com/website/blog
And to check out my current corruption focused wafflings, head here;
And if you’re wondering why they’re both Rotten & Co, it’s because there was a mix up at Wix when transferring packages, a wix-up if you will.