AML POLICY

NOTICE REGARDING ANTI-MONEY LAUNDERING

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Fighting money laundering and terrorist financing contributes to global security, the integrity of the art market and sustainable growth. Laws to combat money laundering and the financing of terrorism are designed to prevent the art market from being misused for these purposes. At Rosetti Firmenich Art Advisory we welcome the new EU legislation regarding Anti-Money Laundering and see it as a positive step for industry and asset class.

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As it seeks to drive financial transparency across the continent, the new EU-wide legislation – the Fifth Anti-money Laundering directive – came into effect on January 10, 2020 which compels art galleries and dealers as obliged entities to mitigate the risks of money laundering occurring in the course of their business. All European Union member states are required to bring 5AMLD into force. 

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As such Rosetti Firmenich Art Advisory now becomes a regulated entity for anti-money laundering purposes. The legislation is mandatory and currently requires verification of the identity of clients when selling or acquiring products.

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Rosetti Firmenich Art Advisory now has an obligation to carry out ‘Know Your Client’ (KYC) checks that are the norm in other regulated markets across the globe, and as such should be familiar to all counterparties. These principles will apply to all clients, whether existing or new, and are irrespective of any geographical borders. Where we are dealing with art advisors acting on behalf of their clients, we are required to run checks on both the advisor and the final client.

The process is straightforward and well known across the banking and corporate sectors, including the auction houses. The legislation is mandatory and currently requires verification of the identity of clients when selling or acquiring products. In detail, individual clients who purchase an artwork for the price of 10,000€ (£8,000) or more, are required to provide Rosetti Firmenich Art Advisory with a valid proof of ID, which could be your passport, driving license or ID card.
 
In case the artwork is purchased by a company, we will require company details such as evidence of incorporation, directors, and the ultimate beneficial owners. However, for private individuals, we may need to collect ID documentation, in the form of a passport or photo ID, when you next transact with us. We will be using a reputable compliance checking company to streamline the process.

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We will require payments to be sent from a bank account held in the name of the person or entity named on the invoice. If the purchase is being paid for by a third party, we will only be able to accept funds following confirmation of the source of the funds in line with these new legal requirements.

Rosetti Firmenich Art Advisory is taking an informed and measured approach to implementing the new legislation in our business. Please be assured that all personal data will be held securely and processed in accordance with current data protection legislation. Please refer to our Privacy Policy on this website.

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Please find more information through the recently published AML Guidelines by the British Art Market Federation (BAMF) and approved by HM Treasury on January 24, 2020.

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If you have any questions or queries, please feel free to get in touch at info@rosettifirmenich.com.