From 10 January 2020, art market participants such as Gildings Auctioneers, who deal in sales, purchases and/or storage of "works of art" with a value of 10,000 euros or more, will be subject to further anti money-laundering obligations, under the Money Laundering Regulations 2017. These are issued by HMRC and are part of an international effort to tackle anti money laundering globally. As part of these obligations, we have to satisfy ourselves with the identity of our clients, be they vendors or buyers. For that reason, we are asking for all clients to provide proof of identity prior to selling or purchasing items with Gildings Auctioneers. We answer some questions that may stem from this throughout this page - Click to expand each question.
Gildings Auctioneers are a registered Art Market Participant with HMRC. We are legally obliged to identify the person we are dealing with in any transaction (buying or selling) or, when dealing with a corporate body or a trust, the person or persons who control that entity. This is often called Customer Due Diligence, or CDD. In providing your ID documents, we are better able to know our clients and fulfill our obligations as a regulated business. A digital copy shall be retained in strict confidentiality and in compliance with our Privacy Policy.
In order to be a client of Gildings Auctioneers we will need to ascertain the following:
In order for us to verify this information, we will need to see one of the supporting documents. Accepted photographic ID includes:
Non-photographic ID must be supported with further proof of address. Government issued documents without a photograph includes:
Examples of other documents to support proof of address includes:
Ideally, we would verify the original forms of ID in person at the saleroom address. We will not accept copies of documents, they must be the originals. We shall then take digital copies and securely store them in compliance with our Privacy policy.
Alternatively, clients can securely upload digital formats (pdf or jpg files) via our website directly to their personal Gildings account. To register for an account click HERE.
Or we may send you an email with a secure link to upload documents to us via a third-party partner – Trust ID.
If you have a Gildings account you can log in and securely upload your own ID documents to your account. Once logged in, go to 'My Account' and then 'Identity Documents' where you will have a drop-down option for Type and then a File Select filed to search for the file you wish to upload on your computer. You can upload JPG or PDF files, but smaller than 2MB. The below is a sample screenshot of where to find this facility:
We store digital copies of the documents on our database in association with your account. We use the information on the documents to verify the information you have registered with us. We may then perform ID checks through our third-party partner Trust ID to further verify the documents. We shall record a document’s expiry date (if applicable) and shall ask you for an updated copy once that date has passed.
Yes, all clients, old or new, will need to provide copies of the ID to continue our business relationship. This may be regarded an inconvenience but we only need to see the documents once.
If you are not willing to provide your ID then we shall not be able to proceed with business, either as a buyer or seller. We will be applying a strict rule of No ID = No Bid.
Corporate customers
Businesses will need to provide the following information and documents supporting:
And for private or unlisted companies
Verification will be accepted from appropriate sources such as
Executors and personal representatives
In the case of an estate of a deceased person in the course of administration, we ask to see:
We will also need full details of the deceased as asked by our Valuations administration team.
Trusts
If you are a Trust appointing our services we will need:
Not all items fall under these Anti Money Laundering regulations, however, as a regulated Art Market Participant we are obliged to perform CDD on all clients regardless of the value of transactions involved.
The AML regulations apply to works of art with a value equivalent to 10,000 euros or more. If you are buying or selling Works of Art over and above this threshold, Enhanced Due Diligence checks will be necessary. A definition of a Work of Art here is derived from s21(6) of the VAT Act 1994. As a brief summary this includes but not solely:
If you would like to discuss any of the content outlined here further please contact our offices - CONTACT US