Stephenson Harwood has published a briefing saying that on 24 January BAMF published its keenly anticipated “Guidance on Anti-Money Laundering for UK Art Market Participants”. It provides clarity on a number of questions on how newly-regulated dealers, galleries and auction houses should apply the Money Laundering Regulations in the course of business. The Guidance clarifies a number of points around the question of when to apply CDD and EDD, and to whom they should be applied – and situations where “double CDD” has to be applied (e.g. where the buyer acts as through an agent), as well as applying CDD at art fairs.
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