What I Do

Comprehensive Compliance Solutions


Anti-Money Laundering

From an initial consultation to reviews and recommendations, I provide a full Anti Money Laundering service to Art Market Participants and IP firms. I work with clients in looking at their businesses to define their Money Laundering risk, and develop policies and procedures specific to their risk. I carry out required statutory risk assessments and guide clients as to how to address the issues that these raise, and to proactively achieve Anti-Money Laundering compliance. 

In addition, given the highly sensitive areas of Suspicious Activity Reporting and the related offence of Tipping Off, I work with clients to develop a documented decision making process for the consideration and submission of Suspicious Activity Reports, for managing SARs submissions internally and dealing with the implementation of discreet employee lines of reporting.

Sanctions

I assist Art Market Participants and IP businesses to assess their Sanction Risk within their client base and their business development target areas. I investigate and recommend what is required operationally, on a day to day basis, to ensure that businesses can move forward without falling foul of this ever growing and demanding area of compliance.

Criminal Finances Act 2017

Within the global sphere, Art Market Participants and IP firms have legal responsibilities about how and who they deal with as third parties. By providing global risk analysis for clients, I identify their risk areas, both domestically and internationally, and provide guided recommendations as to any operational changes that will reduce their risk exposure under the complex Criminal Finances Act 2017.   

Regulatory Compliance

Whether it be with IPReg or direct to HMRC for Art Market Participants, I steer businesses through their ongoing and ever-growing regulatory requirements. This may vary from dealing with initial registrations to implementation of new legislation and guidelines into day to day practice. I help businesses continue to move forward, while addressing the regulatory requirements in their sector.  

The Key to Perfecting Compliance


Internal Awareness and Training

From the top down all Art Market Participants and IP Firms have a responsibility to ensure quality training for all employees, specific to the employees’ roles and responsibilities.

I provide bespoke granular training to ensure employees, directors and owners are fully aware of their Anti Money Laundering obligations and how to deal with “Red Flag” issues.
 
I also provide specific “one to one” and “one to two” training for newly appointed Nominated Persons and Deputy Nominated Persons under the Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) Regulations 2017.

Refresher Training also available for those who might need that little bit of extra focus to keep them up to speed.

Client Due Diligence and Know Your Client

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.

Policies and Procedures

While anyone can buy “off the shelf” packs of policies or procedures, regulators are alert to this and have started rejecting broad brush risk assessments. They are looking for risk assessments and related compliance documentation that is specific not only to your industry, but also the Art Market Participants and IP firms’ individual business.  

My consultancy services ensure that any policy drafted for you or any procedure recommended for implementation for you, is bespoke to your business.

Please get in touch if you would like further information.
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