Anti-Money Laundering Statement

Art market participants

Since 10 January 2020, businesses that trade in works of art, or act as intermediaries in their sale or purchase, are "art market participants" under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended. Bartha Contemporary Ltd is an art market participant. We are supervised by HM Revenue and Customs for anti-money-laundering purposes.

The regulations apply to any transaction, or series of linked transactions, with a value of 10,000 euros or more, or the equivalent in sterling or any other currency. Transactions are linked where they appear to be connected, for example several purchases by the same buyer in a short period, or one price paid in instalments.

When we carry out checks

We carry out customer due diligence on the buyer, and where relevant on the seller, in every transaction within the regulations, before the transaction completes. This applies to new and existing clients, wherever they live.

In addition, as our own policy, we check the identity of every client before a card purchase on this website, whatever the price. We also carry out checks whenever we suspect money laundering or terrorist financing, or doubt information we were given earlier.

What we ask for

Individuals: a valid photographic identity document, such as a passport, driving licence or national identity card, showing your full name, date of birth and nationality, and proof of your residential address.

Companies, trusts and other entities: evidence of incorporation or establishment, the registered address, the directors or trustees, and the identity of every beneficial owner, meaning anyone who ultimately owns or controls more than 25% of the entity or otherwise controls it.

Agents and advisers: where someone buys or sells on behalf of another person, we check both the agent and the person they act for, including that person's beneficial owners.

Politically exposed persons and enhanced checks

If a client or beneficial owner is a politically exposed person, a person who holds or has held a prominent public function, or a family member or known close associate of such a person, we must carry out enhanced due diligence. This includes approval of the transaction by the gallery's senior management, establishing the source of wealth and source of funds, and closer monitoring of the relationship.

We also carry out enhanced checks where a transaction involves a high-risk third country identified under the regulations, where a transaction is unusually large or complex or has no apparent economic purpose, or where our risk assessment shows a higher risk.

Source of funds and payment

We may ask where the money used to pay comes from, and for documents that support your answer. We accept payment only from an account held in the name of the person or entity on the invoice. A payment from anyone else needs our prior agreement and is accepted only after we have completed our checks on the payer. We do not accept cash.

Sanctions screening

We screen our clients and the other contacts in our records each week against the UK Sanctions List, published by the Foreign, Commonwealth and Development Office; the European Union's consolidated list of persons subject to EU financial sanctions; the US Treasury's OFAC lists (the Specially Designated Nationals List and the Consolidated non-SDN List); the UN Security Council Consolidated List; and the Swiss SECO sanctions list. A member of staff reviews every possible match, normally within two working days, and online payment, offers, invoices and payment links for that person are paused until they have. Nothing is reported to an authority unless a member of staff has confirmed the match. We do not deal with anyone who is subject to sanctions, and we report to the Office of Financial Sanctions Implementation where the law requires.

Record keeping

We keep copies of the documents and information obtained in our checks, and the records of the transaction, for 5 years after the end of the business relationship or the completion of the transaction. After that we delete the personal data, unless another law requires us to keep it longer or you have agreed that we may.

Reporting

If we know or suspect, or have reasonable grounds to suspect, that a person is engaged in money laundering or terrorist financing, we must report it to the National Crime Agency. The law may prevent us from telling you that a report has been made. We may decline, delay or cancel a transaction where the law requires it or where we cannot complete our checks.

Your personal data

We process the information collected for these checks because the law requires us to. If you do not give us what the checks need, we cannot complete the sale. Your data is kept secure and confidential and handled in accordance with our Privacy Notice.

Bartha Contemporary Ltd · 7 Ledbury Mews North, Notting Hill, London W11 2AF
Registered in England & Wales, Company No. 07863410 · Registered office: 36 Scotts Road, Bromley BR1 3QD
VAT No. GB 798 9421 55