Criminals alter or deliberately misrepresent the appraised value of high-end assets—such as art, jewelry, antiques, real estate, or other collectibles—to shield or move illicit proceeds, often by forging documentation or staging deceptive transactions. Falsified valuations can inflate purchase prices (to absorb large sums of illegal cash) or deflate them (to minimize outwardly visible wealth). Once resold, the profits appear rationalized by a ‘legitimate’ change in market value, weaving illicit funds into seemingly normal transactions. Offenders may stage multiple sales, label authentic pieces as cheap reproductions, or artificially elevate the price of counterfeits to justify large payments. Similar tactics are used in property deals, where criminals may conduct successive over- or under-valued sales to obscure true ownership or the real source of funds. In some cases, manipulation also extends to digital asset markets where collusive “whales” can distort token or NFT valuations with orchestrated trades, further masking illicit gains.
Asset Valuation Manipulation
Subjective Asset Valuation Manipulation
Subjective Valuation Exploitation
Valuation Manipulation of Art and Collectibles
Commodity and Asset Valuation Manipulation
Asset Value Manipulation
Art Transaction Price Manipulation
Investment in High-Value Assets
Art, Jewelry & Antiquity
Tactics
Repeated over- or under-valued purchases and resales obscure ownership and complicate the tracing of illicit origins, providing a distinct layering dimension beyond the final integration step.
Through falsified or manipulated asset valuations, criminals embed illicit funds into high-value goods (e.g., art, real estate). When resold, the proceeds appear justified by normal market fluctuations, thus completing integration into legitimate commerce.
Risks
Criminals exploit the inherent subjectivity or complexity in appraising high-value items, such as art, real estate, digital assets, and luxury goods, to deliberately overvalue or undervalue them. This manipulation allows them to launder illicit funds by justifying large monetary inflows or outflows as legitimate changes in asset valuations, thereby obscuring the true origin of the proceeds.
Indicators
Transactions where similar assets are sold at markedly different prices, indicating a non-standard, subjective pricing approach inconsistent with established market practices.
Asset transactions that show declared prices significantly deviating from recognized market benchmarks or industry standard valuations, such as artworks or luxury goods priced at multiples above or below typical market values.
Transactions where the asset’s value is based solely on seller or intermediary subjective assessments without any independent third-party appraisal or objective valuation documentation.
Repeated occurrences of price distortions in transactions involving high-value, intangible assets (e.g., art, luxury items) suggesting a deliberate pattern of inflating or deflating asset values.
Inconsistencies between the asset valuation stated in transaction documents and external indicators such as auction results or recognized appraisal reports.
Frequent, unexplained adjustments or revisions in asset values within a short period, lacking clear market-based justification, which may indicate opportunistic manipulation.
Recurring digital asset trades among related parties at artificially high or low prices, indicating wash trading or collusive manipulation of token or NFT valuations.
Data Sources
Specialized systems or services authenticate official documents, such as appraisals or asset certificates. They help detect forged or altered valuation reports and inconsistencies in ownership or provenance records, thereby mitigating attempts to legitimize manipulated valuations.
Contains logs of digital asset and NFT transactions, including amounts, timestamps, wallet addresses, and trading parties. By analyzing patterns of repeated sales between related addresses at artificially high or low prices, investigators can detect wash trading or collusive price manipulation, which are common techniques used to distort digital asset valuations.
Encompasses verified customer information, including personal and business details, financial statements, and documentation of asset purchases or appraisals. This data enables the verification of legitimate valuations by confirming the existence of independent appraisals and identifying missing or forged documentation, which is critical for detecting manipulated valuations.
Provides official records on the ownership, purchase, and transfer of high-value assets (e.g., real estate, fine art, luxury items), including transaction dates, prices, and parties involved. These details enable the detection of over- or under-valued sales, identification of repeated ownership transfers at inconsistent values, and comparison of declared prices with typical market benchmarks—key indicators for uncovering manipulated asset valuations.
Mitigations
Require customers dealing in high-value assets to present independent, accredited appraisals from recognized experts. Cross-check stated valuations with external references, auction records, or standardized price guides to confirm alignment with market norms. Validate the authenticity of the asset and the legitimacy of its beneficial owners to detect deliberately inflated or deflated valuations and prevent concealment behind complex ownership layers.
Configure alerts to flag unusually high or low-valued asset transactions that deviate substantially from typical market ranges. Track patterns of rapid buy-sell cycles where assets are flipped at inconsistent prices, suggesting possible layering or valuation manipulation to launder illicit proceeds.
Deploy specialized blockchain analytics to detect repeated trades among related addresses at distorted prices for NFTs or digital tokens. Flags include wash trading and collusive 'whale' activities that artificially inflate or deflate digital asset valuations to conceal illicit gains under a veneer of legitimate trades.
Deliver targeted training to teach frontline teams how to identify red flags in the appraisal process for art, jewelry, real estate, and luxury goods. Emphasize the heightened scrutiny needed when asset valuations deviate sharply from known benchmarks or rely on obscure, unverifiable appraisers. Instruct staff on escalating anomalies for in-depth review.
Require high-value asset transactions to be conducted via escrow to ensure funds are only released after an independent verification of the asset’s authenticity and fair market value. This process includes reviewing third-party appraisals and validating that declared prices align with typical market ranges before disbursing funds.
Compare stated asset values with data from reputable auction houses, public price databases, real estate registries, or recognized industry publications. By cross-referencing ownership or sale records with open-source evidence, institutions can pinpoint irregularities in appraised values and uncover efforts to pass off inflated or deflated prices as legitimate.
Systematically review documentation and invoices for high-value assets to detect mismatches between declared values, market benchmarks, and recognized appraisal data. Investigate repeated anomalies in invoices, purchase orders, or shipping arrangements that could reveal contrived over- or under-invoicing designed to launder funds through manipulated valuations.
Instruments
- Collusive "wash trading" inflates NFT prices beyond real market demand, enabling criminals to justify large sums as legitimate digital asset sales.
- Subsequent NFT resales at manipulated prices appear like normal market fluctuations, obscuring any link to illicit origins.
- Criminals orchestrate token trades among related wallets at contrived prices, artificially raising or lowering the perceived token value.
- This valuation distortion conceals the actual source of funds, as 'profits' from future token sales appear to stem from typical market appreciation.
- Criminals conduct consecutive over- or under-valued sales to hide true property values and ownership.
- Forged appraisals or deceptive property transfer documents make irregular price swings appear routine, laundering illicit funds under the facade of legitimate real estate deals.
- By misrepresenting the quality or authenticity of jewelry, criminals justify inflated or deflated purchase/sale amounts.
- Forged appraisals or certificates facilitate large financial transfers under the guise of normal jewelry transactions, allowing illicit proceeds to appear derived from legitimate trading activity.
- Criminals inflate or conceal the true value of precious metals and gemstones by falsifying grading, purity, or weight documents.
- This manipulation enables them to launder significant sums through transactions that appear credible in the precious commodities market.
- Criminals forge or falsify provenance documents and appraisals to artificially inflate or understate the value of artwork or rare collectibles.
- Repeated sales at contradictory prices help justify large cash flows as 'legitimate' profit, obscuring the actual source of illicit funds.
- Labeling authentic pieces as cheap reproductions (or vice versa) further manipulates recorded transaction values.
- High-end items (e.g., watches, cars, yachts) can have valuations manipulated through fictitious invoices or staged private sales.
- Criminals artificially raise or lower reported prices, disguising illicit proceeds as legitimate gains or concealing true wealth.
Service & Products
- Offenders fabricate provenance or falsify valuations of art and antiquities, inflating or deflating prices to absorb illicit proceeds or minimize visible wealth.
- The subsequent resale of these assets at a newly manipulated price gives the appearance of legitimate profit or loss, masking the true origin of funds.
- Criminals conduct orchestrated trades (“wash trading”) to artificially boost or reduce token or NFT prices, creating a deceptive transaction history that obscures illicit funds.
- Rapid buy-and-sell cycles can be framed as normal market volatility, making it harder to trace the original criminal proceeds.
- Criminals deliberately inflate or undervalue property prices to hide or move illicit funds under the façade of legitimate real estate deals.
- By repeatedly buying and selling the same property at contradictory valuations, they can obfuscate ownership, disguise proceeds, and create a complex paper trail to justify ill-gotten gains.
- Criminals misrepresent the purity, weight, or value of gold and jewelry to justify receiving or paying large sums of cash.
- Inflated or reduced valuation documents can transform illicit funds into seemingly legitimate proceeds through quick liquidation or staged transactions.
Actors
Traders manipulate digital asset valuations (e.g., tokens or NFTs) by:
- Engaging in wash trading or collusive transactions to distort prices.
- Concealing the original illicit proceeds behind seemingly normal market volatility, complicating financial institutions' efforts to identify manipulated trades.
Real estate professionals are enlisted to:
- Facilitate property sales at artificially high or low prices, allowing criminals to absorb or conceal illicit funds.
- Conduct repeated transactions with inconsistent valuations, obscuring the genuine scale of criminal proceeds and creating challenges for banks verifying legitimate property values.
Professional money launderers orchestrate valuation manipulation by:
- Coordinating with complicit intermediaries, appraisers, or sellers to disguise the true origin and amount of illicit funds.
- Exploiting inaccurate valuations to justify large inflows or outflows of money, hindering financial institutions' transaction monitoring.
Criminals exploit art market participants to:
- Inflate or deflate artwork prices by colluding with or deceiving appraisers and auction houses.
- Conceal the true source of funds and obscure transaction records, hindering financial institutions' ability to assess legitimate value.
Document forgers enable asset valuation manipulation by:
- Creating fraudulent provenance or authenticity documents that justify inflated or deflated asset prices.
- Providing falsified paperwork that misleads financial institutions regarding true ownership or value, obstructing thorough due diligence on high-value transactions.
Dealers in jewelry, diamonds, or other luxury goods are used to:
- Accept falsified valuations for transactions, allowing large amounts of illicit cash to enter the financial system.
- Mask actual wealth or proceeds through intentionally undervalued appraisals, complicating financial institutions' efforts to identify suspicious activity.
References
FATF (Financial Action Task Force). (2007). Money laundering & terrorist financing through the real estate sector. FATF. https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/ML%20and%20TF%20through%20the%20Real%20Estate%20Sector.pdf
FATF (Financial Action Task Force). (2023, February). Money Laundering and Terrorist Financing in the Art and Antiquities Market. FATF. https://www.fatf-gafi.org/publications/Methodsandtrends/Money-Laundering-Terrorist-Financing-Art-Antiquities-Market.html
Lam, K. Y., Chan, B.H., Hartel, P., van Staalduinen, M. (2020, June). Combatting cyber-enabled financial crimes in the era of virtual asset and darknet service providers. INTERPOL. http://www.interpol.int
Al Shamsi, M., Smith, D., & Gleason, K. (2023). Space transition and the vulnerabilities of the NFT market to financial crime. Journal of Financial Crime.https://www.emerald.com/insight/content/doi/10.1108/jfc-09-2022-0218/full/html