ANTI-MONEY LAUNDERING POLICY
Fighting Money Laundering and Terrorist Financing
Rufus Bird Art Advisory (UK AML Registration XHML00000198329) is committed to preventing money laundering, terrorist financing, and proliferation financing in accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended (the "UK Money Laundering Regulations"). Rufus Bird Art Advisory is registered with HM Revenue & Customs as an Art Market Participant (AMP) and is supervised by HMRC for AML purposes.
Customer Due Diligence (CDD) and Know Your Client (KYC)
As a regulated Art Market Participant, Rufus Bird Art Advisory is required to conduct Customer Due Diligence (CDD) checks on all clients, both existing and new, regardless of their location. This includes verifying the identity of both the client and any beneficial owners if the client is a company, trust, or other legal entity.
Verification Requirements
Individual clients: Clients purchasing artwork exceeding £10,000 (or equivalent, whether as a single transaction or a series of linked transactions) must provide valid proof of identity, such as a passport, driving licence, or national ID card, together with proof of address.
Company clients: For companies purchasing artwork, we require documents verifying incorporation, details of directors, and identification of any Ultimate Beneficial Owner(s) holding more than 25% interest in the entity.
Source of funds and wealth: Where a transaction, client, or jurisdiction presents an elevated risk, Enhanced Due Diligence (EDD) will be applied, including verification of source of funds and, where relevant, source of wealth from independently verifiable sources.
Sanctions Screening and Proliferation Financing
Rufus Bird Art Advisory, as an Art Market Participant, is a "relevant firm" under the UK sanctions regime and is subject to a mandatory duty to report actual or attempted breaches of UK sanctions law to the Office of Financial Sanctions Implementation (OFSI). This obligation is separate from, and in addition to, our Customer Due Diligence duties under the Money Laundering Regulations.In line with HMRC guidance, we assess and mitigate the risk of proliferation financing (PF) alongside money laundering (ML) and terrorist financing (TF) risk, with particular attention to high-risk jurisdictions and politically exposed persons connected to them.
Payments
Payments must be made from a bank account held in the name of the person or entity listed on the invoice. For third-party payments, confirmation of the source of funds will be required to comply with the UK Money Laundering Regulations.
Data Protection
All personal data collected during the CDD process will be held securely and processed in accordance with applicable data protection legislation. Please refer to our Privacy Policy for further details.
AML Guidelines
For additional information, please refer to the AML Guidance for UK Art Market Participants published by the British Art Market Federation (BAMF), last updated 6 February 2023 and approved by HM Treasury. Note that this guidance is under review by HM Treasury and HMRC, and may be superseded by new HMRC statutory guidance for the art market in due course — this section should be revisited when that guidance is confirmed.
This statement reflects the UK Money Laundering Regulations as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2026, in force from 30 June 2026, which set the Customer Due Diligence threshold at £10,000 (previously €10,000).