Owing to the transparency Money Laundering Regulations bring, you’ll find that if not properly catered for, your clients details will be required by another Art business so that it can carry out Customer Due Diligence.

Sharing client information between businesses is not the ideal scenario. With an appropriate reliance process in place, it is possible for one business to keep its clients information confidential from the other.

When a business exercises reliance, what information is relied upon is particularly important as you will be liable for any future issues linked to the business on which you are relying.

The evidence on which you rely must also satisfy minimum requirements which extends to include records which indicate you’ve been able to show you have been able to assess customer risk, even if you do not know the ultimate client.

Over the past few weeks, we have been speaking with each of you and it has been interesting to note that many of you are involved in the following transactions with other regulated art businesses where client details would be required:

• Buying and selling at auction
• Sharing ownership of works with other galleries
• Selling works on consignment from other galleries
• Acting as a Agent
• Dealing with Agents

In these scenarios, you’ll require evidence, or another business will require evidence from you.
There are now new features in your account that will cater for all these scenarios, while allowing you and other businesses you are working with to keep your clients' information private from one another. These are explored below.
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If you’ve got questions about Reliance or anything above, please get in touch.

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Reliance Request

If you are dealing with another Art Business who is not using the Arcarta platform, you can send them a ‘Reliance Request’ from your dashboard. The receiving party will then complete a short form serving as a Reliance Report which will be stored in your dashboard.
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There’re lots of instances where this will be useful, consider:
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If you have bought or sold at auction since CDD came into effect in January this year, you’ll need to be capturing and maintaining records for reliance from the auction house.

Due to the newness of the problem expect two things thus far:

• You’ve got nothing from the auction house
• The auction house won’t want to share its clients details with you when you ask

This is symptomatic of the auction house not knowing how to address the issue and not having suitable processes in place to provide you with the information you need.
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Issuing a Reliance Request to your point of contact at the auction house will allow you to satisfy your requirements without causing disruption or treading on toes.

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Share Customer Due Diligence

If you’re dealing with another art business frequently and you do many deals together, using the Share option at the bottom of a Due Diligence report will allow you to Share all evidence or hide your clients details instantly.

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Invite

From today, each time you invite another art business and they join, you’ll both receive a month's free subscription. Consider inviting other art business that:

• Are struggling with AML regulations and Due Diligence
• You conduct business with regularly so you can share evidence of CDD saving effort while keeping your client’s details private from one another
• Is looking to and preparing their business for regulation and registration

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