The purpose of this Anti Money Laundering (AML) policy is to establish a framework for the detection and prevention of money laundering activities at Gallery Sorelle Sciarone. We are committed to adhering to international standards for Customer Due Diligence (CDD) as outlined by the Basel Committee. This policy applies to all sales and financial transactions conducted by the gallery. 

1. Customer Acceptance Policy

We have a stringent Customer Acceptance Policy (CAP) in place to ensure that all new customers are thoroughly vetted before any transactions occur. The following procedures will be followed:

• Verification: We verify the identity of every new customer before accepting any payments or engaging in any business transactions. That means no cash transactions and collectors fill in their information on the website that is kept for a set period of time in accordance to our Privacy Policy
• Documentation: Customers must provide valid identification documents, which may include a passport, driver’s license, or any government-issued ID, along with proof of address for artwork sales over €5.000,00. Artwork priced lower, an address and contact details is needed for our documentation due to Intellectual Property rights artist keep after the sale of an artwork to a collector.
• Due Diligence: We conduct background checks using publicly available information and databases to confirm the legitimacy of the customer or company.
• Approval: No business relationship will be established without the explicit approval of the gallery owner, Tascha Sciarone.

2. Customer Identification Policy

In compliance with the Basel Committee standards, we will not enter into a business relationship until the customer's identity has been verified. This is for purchases over €5.000,00. The procedures include:

• Identity Verification: Customers must present official identification documents which will be recorded and stored securely.
• Proof of Address: Customers must provide recent utility bills or bank statements to confirm their residential address.
• Business Verification: For corporate customers, we require incorporation documents, tax ID's, and information on the beneficial owners.

3. Monitoring Risks and Transactions

We have established a robust system for monitoring and reporting suspicious transactions:

• Transaction Monitoring: All transactions are monitored for unusual or suspicious activity using our electronic payment system.
• Red Flags: Transactions that are unusually large, complex, or inconsistent with the customer's known activities will be flagged for further investigation.
• Reporting: Suspicious transactions will be reported to the relevant authorities in compliance with local regulations. Detailed records of such transactions will be maintained.

4. Risk Management

Risk management is a critical component of our CDD policy. The following measures are in place:

• Compliance Officer: Tascha Sciarone, the gallery owner, is designated as the Compliance Officer responsible for overseeing and implementing this AML policy.
• Risk Assessment: Regular risk assessments will be conducted to identify, assess, and mitigate potential money laundering risks.
• Record Keeping: Detailed records of customer identification, transactions, and reports of suspicious activities will be maintained for at least five years. Privacy Policy

5. Employee Training

Although currently, Tascha Sciarone is the sole employee handling finances, the following procedures will be adhered to:

• Training: Tascha Sciarone will undergo regular training on AML regulations, CDD procedures, and how to identify and report suspicious activities.
• Procedures: Up until now (2024) all suspicious transactions were denied and ignored. Suspicious individuals were blocked and scam emails deleted and moved on from. From now on a list will be kept and reported on. Especially as we have always handled it as risk to our business, but never stood still that we should report what we had thought were just scams.

6. Privacy Policy

We are committed to maintaining the privacy and confidentiality of our clientele. All customer information and documentation are stored securely and only accessed by authorized personnel. We ensure compliance with data protection regulations to safeguard our clients' privacy.

7. Policy Review

This AML policy will be reviewed annually or as required to ensure compliance with evolving regulations and standards. Updates will be communicated to all relevant parties.

This policy demonstrates our commitment to preventing money laundering and ensuring the integrity of our art gallery's operations. By adhering to these procedures, we aim to protect our business and clients from the risks associated with money laundering activities.