Anti-Money Laundering & Identification Policy
Gorringes is committed to full compliance with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) legislation in the United Kingdom. As part of these obligations, we may request and verify identification from clients, vendors, buyers, and other parties engaging in transactions with us.
Legal Framework
Our AML obligations arise under UK law, including (but not limited to):
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
- The Proceeds of Crime Act 2002
- The Terrorism Act 2000
These regulations require businesses such as auction houses to undertake customer due diligence and maintain appropriate controls to prevent financial crime.
Why We Request Identification
To comply with our legal obligations, Gorringes may request identification and supporting documentation in order to:
- Confirm the identity of our clients and, where applicable, beneficial owners
- Verify source of funds and, where necessary, source of wealth
- Assess and manage the risk of money laundering or terrorist financing
- Conduct ongoing monitoring of business relationships and transactions
When Identification May Be Required
We may request identification at various stages, including:
- Before establishing a business relationship
- Prior to completing certain transactions, particularly those meeting regulatory thresholds
- Where there is a change in client circumstances or transaction patterns
- Where we are required to update or refresh existing client records
Types of Identification
We may request documents such as:
- Valid photographic identification (e.g. passport or driving licence)
- Proof of residential address (e.g. utility bill or bank statement dated within the last three months)
- For corporate entities: company registration documents, ownership structure, and details of directors and beneficial owners
Additional documentation may be required depending on the nature of the transaction or risk assessment.
Failure to Provide Information
Please note that if satisfactory identification or verification documentation is not provided when requested, Gorringes may be unable to proceed with a transaction or continue a business relationship. This is a legal requirement and not discretionary.
Data Protection
All personal data collected for AML purposes will be processed in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Information will be used solely for compliance purposes and retained only for as long as required by law.
Ongoing Compliance
Gorringes reserves the right to request additional information or documentation at any time in order to meet its ongoing legal and regulatory obligations.
