Churchill Auctioneers Anti-Money Laundering (AML) Policy

Effective Date:

1st July 2024

Issued by:

Churchill Auctioneers

Last Reviewed:

1st January 2025

1. Introduction

Churchill Auctioneers is committed to conducting business in accordance with all applicable laws and regulations related to anti-money laundering (AML) and counter-terrorist financing (CTF). This policy outlines our requirements and expectations of customers when engaging in transactions with us, whether online or in person.

2. Our Legal Obligations

As an Art Market Participant (AMP) and Auction House, we are regulated under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. We are required to identify and assess risks, carry out customer due diligence (CDD), and report any suspicious activity to the appropriate authorities.

3. Customer Responsibilities

By participating in sales or consignments through Churchill Auctions Ltd you agree to:

– Provide Valid Identification: You must supply acceptable identification when requested. This applies to both buyers and sellers, and may include:

  • A valid passport or photo driving licence
  • Recent utility bills or bank statements (dated within 3 months)
  • Corporate documents for companies (e.g., certificate of incorporation)

– Confirm Source of Funds: You may be required to declare and provide evidence of the legitimate source of funds for significant transactions (typically €10,000 or more, including linked transactions).

– Avoid Third-Party Payments: We do not accept payments from or on behalf of third parties unless we have conducted due diligence on the payor. Payments must be made from accounts in the name of the registered buyer.

– Comply with Sanctions: We do not conduct business with individuals or entities listed on UK, EU, or UN sanctions lists.

4. Enhanced Due Diligence (EDD)

We are required to conduct enhanced due diligence in certain situations, including but not limited to:

– High-value or complex transactions

– Politically exposed persons (PEPs) or those closely associated

– Customers from high-risk jurisdictions

In such cases, we may ask for additional documentation or information before proceeding with any transaction.

5. Suspicious Activity Reporting

If we suspect that a transaction may involve criminal property or may be intended to disguise the origin of funds, we are legally obliged to report this to the UK National Crime Agency (NCA). In such instances, we may be required to delay the transaction or refuse to proceed.

We are not permitted to inform customers if a report has been made (this is known as “tipping off” and is a criminal offence).

6. Privacy and Confidentiality

All personal data collected in the course of AML compliance will be processed securely and only used for legitimate compliance purposes, in line with the UK GDPR .

7. Contact

If you have any questions regarding this policy or how it affects your transactions with Churchill Auctions please contact our Compliance Officer at info@churchillauctions.co.uk

8. Updates to This Policy

We reserve the right to update this policy to reflect changes in regulation or business practices. The latest version will always be available on our website.