However, registration by itself does not constitute compliance and panel speakers at the event, held in London on November 2, encouraged AMPs to ensure they are following all the required processes.
Paula Trommel, deputy director of Corinth Consulting, reminded participants they needed to conduct a risk assessment, put policies in place and provide training to staff. “And write everything down,” she affirmed, to ensure there is an audit trail that can be shown to authorities in case of an investigation.
Under the directive, AMPs – any auction house, dealer or anyone trading in or acting as an intermediary in the trade of works of art – are required to verify identities and conduct appropriate due diligence checks on customers if they expect to transact at values of €10,000 or more.
The legislation also covers any series of lower-value ‘linked transactions’ that can add up to €10,000 or more, irrespective of the method of payment.
Other sessions at the conference covered how art market businesses survived during lockdowns and how they have changed since, while a panel discussion on the burgeoning market for non-fungible tokens (NFTs) went some way to persuading delegates that it is more than just a speculative bubble that is about to burst.
A show of hands in the room at the end of the day revealed that as many delegates – about a dozen – had a cyberwallet (typically needed for buying NFTs which are most often traded in cryptocurrency) as had a £20 note in their physical wallet, perhaps demonstrating that both the cashless economy and the world of cyber art trading are becoming increasingly mainstream.