Not only is it essential for Art Market Participants and IP firms to know who their clients are, it is also vital for them to keep records of their due diligence and on-boarding of clients. The introduction of these tasks is probably the most significant and time consuming of all tasks in the new legislation. However, with clients I develop a process for them to understand the levels of due diligence required – simplified, standard or enhanced, according to the clients’ legal identity eg individuals, limited company, trust, foundation etc.
I work with clients so that operationally the bespoke embedding of a new process for clients and their due diligence responsibilities achieves compliance with all relevant Financial Crime legislation. This new client due diligence process can then be extended to include the ongoing responsibilities of clients carrying out required Know Your Client checks and investigations going forward.