ANTI-MONEY LAUNDERING POLICY

Anti-money laundering policy

As many of you will know the Government has introduced new anti-money laundering measures which affect clients of all artists, art dealers, galleries and auction houses, regardless of past associations.

In line with these measures we have to take all reasonable steps to mitigate the risks of money-laundering occurring in the course of our business, including the risk of being paid with illegally obtained funds.

Before a commission can proceed or the completion of any sale, we need to carry out Customer Due Diligence. These checks are broadly similar to those carried out by banks when you open up a bank account. Please understand that we are now obligated to do this for all our clients, even those with whom we have dealt in the past. However, we are committed to make the process as quick and efficient as we possibly can. Along with many other reputable galleries we have signed up with Arcarta, a company which specialises in art market Due Diligence.

For individuals, Arcarta will require a copy of a valid photo identity document such as a passport, driving license or national ID card which confirms full name, date of birth, nationality and proof of permanent residential address. For companies, Arcarta 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 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, we reserve the right to refuse third party payments.

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

We thank you for your understanding and co-operation, if you have any questions please contact Sara on 020 7839 2792.