Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/59

 of money laundering or terrorist financing, enhanced due diligence, client risk reviews and KYC checks may be required." The 2018 AML Policy poses two questions for Christie's employees to consider regarding KYC procedures:


 * Am I satisfied that the person/entity I am dealing with is the person/entity they claim to be?
 * Do the circumstances of the proposed transaction give rise to a suspicion that the property being sold or funds used for payment are derived from criminal activity or may be used to fund terrorism?

The 2018 AML Policy also states "for clients who are legal entities, Christie's must also identify the natural persons in control (e.g., directors and beneficial owners)." Christie's requires certain forms of identification for individuals making purchases or the beneficial owner of a private company, including offshore entities.

Christie's also notes circumstances that are considered "red flags." The document explains that red flags "are indicators of circumstances where [Christie's] may require further information from or about the client" and provides specific examples.

Sanctions Policy. The current Christie's sanctions policy was issued on May 1, 2018. It states that "Christie's is committed to complying with all Sanctions that may apply to its business at any given time." As such, employees and representatives must not "enter into or facilitate any business, dealings, or other activities, directly or indirectly, involving or for the benefit of Sanctioned Parties, except where expressly approved in writing by Compliance."

The Christie's Sanctions Policy delineates certain countries as high risk countries and requires "all potential business and relationships with clients, suppliers and other third parties in High Risk Countries [to] be referred to Compliance prior to any business being conducted or any business relationship being established." The policy also states that "Christie's will ensure that employees in specific regions and departments exposed to dealings with High Risk Countries received appropriate training on Christie's Sanctions obligations."