ANTI-MONEY LAUNDERING POLICY

The government has introduced new anti-money laundering measures which will affect all art dealers, galleries and their clients as of 10th January 2020 throughout the EU.

We will have to take, and be seen to take, all reasonable steps to mitigate the risks of money-laundering occurring in the course of our business, including the risks of being paid with illegally obtained funds.

As part of these obligations and before the completion of any sale, we will be legally obliged to carry out identification and Customer Due Diligence on all clients. These checks are broadly similar to those carried out by banks when you open up a bank account and have already been put in place by the major international auction houses.

For individuals, we will require a copy of a valid photo identity document such as a passport, driving license or national ID card which confirms their full name, date of birth, nationality and proof of permanent residential address. For companies, we will require company details including evidence of incorporation, directors and the ultimate beneficial owners. In a situation where an agent/advisor is acting on behalf of a buyer, we may be required to identify the ultimate buyer in addition to the agent.

Payments received by the gallery will have to be received from a bank account held in the name of the person or entity named on the invoice. In the event that you wish for a third party to pay for a purchase on your behalf, you will have to seek our prior authorisation to do this and if the information you provide to us doesn’t meet with these new legal requirements, unfortunately we will have to reserve the right to refuse third party payments.

Please understand that we are now obligated to do this for all our clients spending more than £8,600, even those with whom we have dealt in the past, but rest assured that we will do our best to make the process as quick and efficient as we possibly can.

We assure you that the information which you provide to us will be held and processed in accordance with our privacy policy and will remain secure and confidential at all times.

If you have any questions please contact us.