Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/60

 Christie's Briefing. Employees from Christie's U.S.-based legal department in New York briefed Subcommittee staff on Christie's anti-money laundering policies and sanctions compliance, led by Christie's General Counsel for Dispute Resolution and Legal Public Affairs ("Christie's General Counsel"). According to her, the Legal Department acts as a "helicopter parent," serving as an independent check on Christie's business activities. She noted that the AML policy applies to all employees, including client-facing employees, because Christie's "wants [all employees] to know they are responsible for [compliance] issues." The Legal function serves as "an independent check away from the business to look at all decision being made" to ensure appropriate compliance. The Compliance Manager for the Americas added that there are "conversations between [client-facing] front line staff to alert [Legal] to red flags." He continued that "if a client gives [client-facing staff] pushback it would be an immediate escalation to Legal." Regarding Christie's AML policies, Christie's General Counsel noted that they are applicable to all Christie's employees globally. Additionally, all Christie's employees receive training on the policies.

Christie's General Counsel noted that the Legal Department has the ability to "restrict" clients—such as sanctioned individuals. Restricting a client "blocks" them globally from transacting with Christie's. Only the Legal Department is able to place or remove these restrictions. The decision to restrict someone with derogatory information is simple; the Legal Department can simply say "no" and restrict that individual from transacting with Christie's. If information is less clear, the decision is escalated to the head of the compliance department through a report. If necessary, the issue can subsequently be escalated to the General Counsel in London or further to the Deputy CEO for a decision.