Whilst art market sellers are permitted to outsource various AML/KYC services, provision of those services does not relieve the seller of their overall compliance requirements under UK law which may not be delegated.
Partnership with Art Money does not:
- Change the requirement for art sellers (AMP’s, art market participants) to register with HMRC and have a compliant and ongoing training program including a nominated in-house MLRO (Money Laundering Reporting Officer).
- Remove the requirement to be aware of and act on ‘Red Flags’ beyond the identification and verification services (ie outside the remit of Art Money services).
For example, if Art Money verifies a buyer/collector and the transaction is invoiced to that Verified Buyer, but the payment comes from a different person and/or the property is delivered to yet another person, these facts may be Red Flags about which Art Money would have no knowledge and for which the art seller has sole responsibility.