Anti-Money Laundering

In early 2020, the UK government introduced new anti-money laundering measures for all art dealers, galleries, and their clients. Hidden is required to take all reasonable steps to mitigate the risks of money laundering occurring during our business, including the risks of being paid with illegally obtained funds. 

 

As part of these legal obligations and before the completion of any sale over the sterling equivalent of 10,000 euros, Hidden must conduct identification and screening checks similar to those already carried out by financial institutions, financial advisors and major auction houses. Hidden use Arcarta - a secure due diligence platform - to conduct these checks. A member of our team will send you a link to Arcarta, which will take you through the steps of uploading the necessary information. This should only take 5 minutes to complete and can all be done on a mobile phone or laptop. For more information on Arcarta, please see page 2. As a client or prospective client of Hidden, we kindly ask you to provide us with the following documentation for us to fulfil our legal obligations. 

 


 

  • If you are a private individual;

     

    Required Documents: 

    1. A copy of a valid photo identity document such as a passport, driving license or national ID card that confirms your full name, date of birth and nationality.

    2. A copy of a proof of address that confirms your permanent residential or billing address.

     

    Please note that you may be asked to provide evidence of confirmation as to the source of the funds being used. We will specifically request this from you if it is needed. If you wish to have the artwork(s) delivered to a secondary address such as a holiday home, you must provide an additional 2 proofs of address for the property.

     

     

    If you are buying through a company or other corporate entity;

     

    Required Documents: 

    1. Company name and number, and documents to evidence: country of incorporation; registered address; trading address (if different to registered address); names of the current director(s) and the ultimate beneficial owner(s). *

    2. Photo ID and proof of address for each person with significant control (25% or more of the share capital or voting rights in the company, or who otherwise exercises control over the management of the company). Please see column 1 for a list of required documents. 

     

    Please note that you may be asked to provide evidence of confirmation as to the source of the funds being used. We will specifically request this from you if it is needed. * If a company is owned by a corporate entity, evidence of this (e.g., register of shareholders or members) showing the chain of ownership, until all individuals are accounted for, is required. 

     

     

    If you are an intermediate buying on behalf of a 3rd party

     

    If you are buying on behalf of a 3rd party, rather than buying into stock, we are required to identify the ultimate buyer in addition to the agent. 

    If the ultimate owner is a private individual, please refer to column 1 for a list of required documents. 

    If the ultimate owner is a company or other corporate entity, please refer to column 2 for a list of the required documents. 

     

    Payments to the gallery must be received from a bank account held in the name of the person or entity named on the invoice. If payments are made from a joint bank account, you may be required to submit documents for both individuals. If you wish for a third party to pay for a purchase on your behalf, you will have to seek our prior authorization. If the information you provide us does not meet these new legal requirements, unfortunately we have the right to refuse third party payments. 

     


     

  • Additional Guidance: What and How to Submit

    Photo ID

     

    Government-issued documents with a photograph include: 

    • Valid passport 

    • Valid photocard driving licence (full or provisional) 

    • National Identity card 

    • Firearms certificate or shotgun licence 

    • Identity card issued by the Electoral Office for Northern Ireland 

     

    Please ensure that photographs or photocopies of the ID are clear and shown in their entirety i.e., so that all edges of the document are visible. If submitting a passport, please ensure that the entire photo page is visible, including the characters shown along the bottom of the page. ID must be valid and in date to be accepted. Where possible, please submit colour photographs or photocopies of the ID to aid legibility. 

     

     

    Proof of Address

     

    Acceptable proofs of address include: 

    • Utility bill (gas, electric, landline phone bill) from a regulated utility company issued within the last three months. 

    • Local authority council tax bill, statement, or demand letter for the current council tax year. 

    • Current UK driving licence (but only if not used for the name evidence). 

    • Bank statements, or credit/debit card statements, issued by a regulated financial sector firm in the UK or EU Bank    dated within the last three months. 

     

    Please note that you cannot use one form of identification to prove both name and address. For example, if you provide your driving licence as proof of your name, you must provide another form of identification for your address, such as a utility bill. 

     

    For more information on HMRC’s requirements, Click here.

     

     

    Stored Information, Privacy and Security

     

    We are legally obliged to maintain and store customer due diligence evidence on Arcarta for a minimum of 5 years.

     

    The images and information supplied will be stored on Arcarta, a government approved platform, in the same way that it would be for a bank or other financial institution. Only Hidden has access to the information within your Arcarta account. Our privacy settings are configured so that only the account administrator has access to the documents submitted after the checks have been conducted and approved. 

     

     

    How your data is stored on Arcarta 

     

    All data is stored with AWS and GCP and where a location can be specified it is EU-Ireland. The database is a multi-AZ RDS instance in the EU. Two-Factor Authentication is in effect on all accounts, and encryption at rest applies to all database replication/backup snapshots. Point-in-time recovery of all data is available on both the writer and reader for the last 12 hours. All files are accessed using a cryptographically signed URL for an authenticated user; files are not publicly available on the internet and these URLs expire within 15 minutes.

     

    Arcarta is independently audited, and the most recent audit was performed by Cambridge-based Fidus Information Security that has worked with Barclays and The Economist. The Arcarta platform is presently used by over 400 members of the international art market including Single and Multi-Family Offices acting on behalf of UHNW clients as well as Publicly listed companies such as 1stDIBS.

     

    No member of the Hidden team has the information or documents that you provided saved; it is all stored securely on Arcarta.