This guide outlines the tools we've added to your contacts section to help manage Customer Due Diligence, and provides links to further resources.
The Anti-Money Laundering Directive 5 is new legislation introduced by the EU, requiring that the sale of one or more artworks (or a series of linked purchases) that exceed the equivalent sum of €10,000 (inclusive of taxes), has a Customer Due Diligence check performed on the client.
Artlogic has taken direct guidance from HMRC to help our clients manage this legislation. Artlogic's contacts database is too much of an open forum to store the identity and proof of address documents (e.g. copies of passports, phone bills, etc.), or risk assessment scores. HMRC has advised that documents associated with Suspicious Activity Reports have to be stored securely and separately to other customer files in systems that only Nominated Officers, their deputies or Compliance Officers can access. Clients will, therefore, need to use external systems for storage of AML risk assessments and related documentation. A google search for 'AMLD5' or 'KYC' (Know Your Customer) may help understand the process and find products to help you.
Further information, including documentation and a variety of useful resources, can be found on our website: https://artlogic.net/aml.
Customer Due Diligence (CDD) Tools in your database
While Artlogic cannot store your CDD documents, we have built tools into the contacts section of your database to make managing this easier.
Turn on the Core Preference to get started
To use this functionality, ensure that the preference is switched on in Other > Admin > Preferences > Core Preferences > Contacts > Compliance Features and toggle on AMLD5 compliance features (it is on by default).
If storing copies of CDD check documents digitally in another cloud-based system (these documents cannot be stored in your Artlogic database alongside contact details), a link can be provided in the 'AML risk assessment external system URL' field to where these will be accessed.
User Roles and Access
All administrators can access CDD information. To grant this information to users who are not administrators you can go to Other > Admin > Users (click pencil tool to edit user) > Roles > Contacts > 'This user may edit AML D5 compliance fields'.
CDD Tools in Contacts
CDD check information is stored on a Contact Edit page on the general tab. These are the fields that will show:
- CDD status to show if a CDD Check has been obtained.
- CDD check by
- CDD date
- Display expiry warning. CDD checks will automatically expire after one year. If the documents used in the CDD check expire in less than a year, users have the option to be reminded on that day. You can also Disable warnings if conducting a CDD check on a client that is unlikely to make another purchase within the next year.
If the URL to the external documents has been provided on preferences, a link will appear:
CDD Tools on the Preview Pane
Once CDD Obtained has been ticked, a flag will appear on the preview panel in your contacts.
If the User has AMLD5 privileges and is on a desktop or tablet, this ‘flag’ is a clickable link that will open up the CDD check fields.
If the CDD check is no longer valid, the green ‘tick’ will change to an orange warning.
The flag will disappear from the preview panel if CDD Obtained is unticked and the user clicks Save, or if the CDD check is no longer valid and the user clicks Disable warnings, then clicks Save.
Searching and Exporting
In your Contacts Advanced Search you can search:
If the CDD check was obtained
The date of the CDD check
The expiry date (if provided)
Which user conducted the check
These fields can also be exported using the Custom Export functionality. These fields will not show if AMLD5 compliance is switched off in Core preferences.