Anti-Money Laundering Policy
Erskine, Hall & Coe is compliant with the anti-money laundering regulations that took effect in the UK on the 10th of January 2020, and as such, we are obliged by law to perform customer due diligence on our clients who are involved in any transaction over €10,000.
Satisfactory evidence of the client’s identity is required before the transaction is carried out. This applies to new and existing clients, irrespective of how long we have known them or where they are geographically based. For individuals, we require a copy of valid photographic identification, such as a current passport, driving license or national ID card, along with a document providing proof of address, such as a bank statement or utility bill which is no more than three months old. For companies, we require additional information, including but not limited to a copy of their certificate of incorporation or articles of association, confirming their beneficial owner(s) or the person(s) holding significant control. In the event where an agent or advisor is acting on behalf of a buyer, we must obtain the same proof of identity for the ultimate buyer.
While we may agree a sale, we will not be able to complete it (i.e. receive payment or give up possession of the artwork) until we have received all necessary evidence from the client and have been able to verify it as required by the regulations. We reserve the right to use third party services such as credit and identity check companies and websites to conduct our due diligence on any client.
We must retain copies of the evidence provided by all clients for five years after the end of our business relationship or completion of the occasional transaction.
Payments received by our gallery must have come from a bank account held in the name of the individual or entity to whom the sales invoice is addressed. If a client wishes for a third party to settle an invoice on their behalf, they must obtain our authorisation prior to the payment being sent. We must be satisfied as to the source of the payment, and reserve the right to refuse third party payments if the information provided to us does not adhere to the legal requirements.
We have a professional and legal obligation to client confidentiality; however, if we develop a suspicion that money laundering or terrorist financing may have taken place or is being attempted, we are required to report it to the National Crime Agency.