Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/63

 adopted such an approach, giving particular regard to our circumstances, such as our commercial activity, our range of clients and the registration process." The 2018 Bonhams Manual identifies the following risk areas:

"Type of client—Is the client a private individual or corporate entity? Is the client acting as a principal or agent? Are they an existing or new client? Are you visiting the client in their home or are you seeing them for the first time when they have walked in off the street?

Type of customer—Is the customer present at the sale? Does the customer mix business and private transactions?

Geographical—Where is the client situated?

Transaction/Payment type—How does the buyer settle his/her invoices? How is the vendor paid?

Ongoing monitoring (Behavior) & other risk factors
 * Is the transaction consistent with the client's payment history?
 * Is there any unusual or erratic behavior displayed by the client?
 * Are there any indicators that raise concerns that the transaction is suspicious?
 * A combination of the various criteria should help determine the client's risk category?"

The 2018 Bonhams Manual continues:

"However, it is ultimately the member of staff's professional judgment that will determine whether a client or particular transaction requires further examination.

The higher the risk level of the client, the more scrutiny should be applied before entering into business relations with a client. If it doesn't 'Smell' right, tell us!"

The 2018 Bonhams Manual also requires that a vendor provide identification. Further, an "agent as consignor should disclose to [Bonhams] who their 'principal' is (especially if that person is not signing the contract) in  the Master Consignment Agreement (MCA) before the agent signs." The document continues: "Bonhams should request or seek confirmation of agency or representation relationship (as