The art trade market is global, highly fragmented and complex, involving a great variety of operators. In light of this complexity, the current level of regulation and existing compliance efforts by individual operators has proven to be insufficient. With some competitors engaged in unethical or illegal behaviour, operating profitably while acting with integrity and ethics is increasingly difficult.

The transition process in many countries in Central and Eastern Europe from a one-party state to a democratic system has been long and difficult and has frequently been accompanied by institutional instability.

The judiciary and law enforcement bodies have been no exception. Both have suffered from a weak legal tradition in many countries of the region, weak implementation of existing legislation, limited operational effectiveness, corruption and the influence of informal personal networks. These developments can also be observed in the area of financial intelligence.

Intensified economic globalisation has had positive and negative effects. It has left nation states struggling to deal with the negative fall-out. National regulation against abuses has, however, proven increasingly ineffective, especially since companies have the freedom to move their hazardous activities to under-regulated areas.

This paper examines how the Wolfsberg Anti-Money Laundering Principles came into being. It charts their subsequent development and also looks at what the Wolfsberg Group of banks may tackle in the future.

Switzerland is frequently accused of being reluctant to take thorough measures to fight money laundering. Both the Swiss authorities and the banks in Switzerland strongly reject such accusations. We are convinced that our anti-money laundering measures are best market practice.