Notice of new anti-money laundering (AML) legislation
Effective from 10 January 2020, new anti-money laundering legislation requires all new and existing clients to provide identification when purchasing an artwork. Please read the below for a brief summary of what the legislation will entail.
Anti-money laundering (AML) legislation
The government has introduced new anti-money laundering measures which will affect all art dealers, galleries and their clients as of 10th January 2020. This is an EU wide legislation to which the UK will abide irrespective of Brexit. Similar legislation is also expected to be introduced in the US in the near future.
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, Black Box Projects will be legally obliged to carry out identification and screening checks on all clients buying from our gallery. 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 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 will 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.
We ask you to bear with us whilst we carry out these mandatory checks before the completion of a sale of a work of art. Please understand that we are obliged to do this for all our clients, even those with whom we have dealt in the past and have long-standing relationships, but rest assured that we will do our best to make the process as quick and efficient as we possibly can.
If you have any questions please contact firstname.lastname@example.org.