Yacht brokers face significant AML risks due to the diverse nature of super-yacht charter clients, which range from HNWIs, family offices, corporations, intermediaries, PEPs, celebrities, and private wealth vehicles such as trusts or foundations. These client types often bring complexity, such as opaque ownership structures, third-party payments, potential PEP exposure, sanctions risks, and tax avoidance schemes, all of which heighten the possibility of money laundering or reputational damage. Common red flags include reluctance to disclose UBOs, vague explanations of funds, sudden offshore payments, inconsistent or forged documentation, unusual itineraries involving high-risk jurisdictions, and pressure to bypass due-diligence checks.
Yacht brokers occupy a complex and uneven position within international anti-money laundering (AML) frameworks. Under the EU’s 4th and 5th AML Directives (AMLD4/5), they are not explicitly listed as obliged entities. Instead, they are captured indirectly under the category of dealers in high-value goods, which requires compliance only when cash transactions of €10,000 or more are involved. As most yacht sales and charters are conducted through bank transfers, this structure has left a regulatory gap, with many transactions falling outside the EU’s mandatory AML perimeter. This has created significant divergence at national level: while some member states have adopted extensions that explicitly bring yacht brokerage into scope, others remain tied to the baseline cash-triggered obligations.
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08/2025