ANTI-MONEY LAUNDERING POLICY
Last updated: September 2026
3 – IDENTIFICATION, REPRESENTATION AND BENEFICIAL OWNERSHIP
a) Identification and representation
b) Beneficial ownership and legal structures
4 – PURPOSE, STRUCTURE AND COHERENCE OF THE TRANSACTION
a) Purpose and nature of the relationship or transaction
b) Source of funds and, where applicable, source of wealth
5 – ENHANCED DUE DILIGENCE AND RISK FACTORS
6 – PAYMENTS AND THIRD-PARTY INVOLVEMENT
a) Payer and source of payment
b) Third-party payments, split payments and refunds
7 – ONGOING MONITORING AND UPDATING OF INFORMATION
8 – UNUSUAL TRANSACTIONS AND RESTRICTIONS ON EXECUTION
a) Review of unusual or attempted transactions
b) Non-execution, suspension or termination
c) Confidentiality
9 – DOCUMENT RETENTION AND COOPERATION WITH THE AUTHORITIES
1 – PURPOSE AND SCOPE
This Policy sets out the general framework under which Monterone Art applies the anti-money laundering and counter-terrorist financing measures required in connection with its activities and transactions.
Monterone Art is subject to the applicable legislation in this area insofar as it carries on activities involving the professional trade in works of art or antiques, or acts as an intermediary in such trade.
This Policy shall apply to relationships and transactions that are subject to anti-money laundering or counter-terrorist financing obligations.
Depending on the nature of the relationship or transaction, and where required under applicable law, the relevant measures may apply to clients, buyers, sellers, consignors, representatives, intermediaries, payers, beneficial owners and any other natural or legal persons involved in the relevant relationship or transaction.
The scope and level of the measures to be applied shall be determined in accordance with applicable law and the relevant level of risk, in line with the criteria set out in the following sections of this Policy.
2 – RISK-BASED APPROACH
Monterone Art shall apply customer due diligence measures with a scope and level of intensity proportionate to the money laundering or terrorist financing risk associated with each relationship or transaction and to the circumstances of the persons involved.
Where relevant, the risk assessment shall take into account the characteristics of the client and the other parties involved, the nature, purpose, value, complexity and structure of the transaction, the methods and circumstances of payment, the jurisdictions concerned and any other relevant factors. These elements shall be assessed collectively, and the presence of any individual factor shall not, in itself, determine the overall risk classification, except where applicable law provides for a specific consequence.
Where permitted by applicable law and justified by the level of risk identified, Monterone Art may adjust the scope, intensity or frequency of certain customer due diligence measures. Where a higher level of risk is identified, doubts arise as to the information obtained, or circumstances give rise to concerns requiring further scrutiny, the appropriate additional or enhanced measures shall be applied.
The information, documentation and verification measures required in each case shall be determined by reference to the risk identified and the applicable legal obligations, without extending such measures beyond what is necessary to ensure appropriate compliance.
3 – IDENTIFICATION, REPRESENTATION AND BENEFICIAL OWNERSHIP
a) Identification and representation
Monterone Art shall identify and, where required, verify the identity of any natural or legal person seeking to establish a business relationship or participate in a transaction, on the basis of reliable documentation and, where appropriate, other reliable sources of information.
Where a person acts in the name or on behalf of another person or entity, Monterone Art shall, to the extent required, verify the identity of the representative and of the person or entity represented, as well as the existence and sufficiency of the authority under which the representative acts.
The information and documentation provided must be sufficient, accurate and up to date to enable the appropriate customer due diligence measures to be carried out.
b) Beneficial ownership and legal structures
Where required, Monterone Art shall identify the beneficial owner of the relationship or transaction and take appropriate measures to verify their identity in accordance with applicable law.
In the case of legal persons, trusts, foundations, associations or other entities or arrangements, Monterone Art may request such information and documentation as is necessary to obtain a reasonable understanding of their ownership or control structure and to identify the natural persons who ultimately own or control them, benefit from them, or on whose behalf the relationship is established or the transaction is carried out.
Where the ownership, control or representation structure is not sufficiently clear from the information available, Monterone Art may request such additional explanations, documentation or verification as may be necessary to determine the beneficial ownership.
4 – PURPOSE, STRUCTURE AND COHERENCE OF THE TRANSACTION
a) Purpose and nature of the relationship or transaction
Where appropriate, Monterone Art shall obtain sufficient information to understand the purpose and nature of the relationship or transaction, as well as the client’s professional or business activity where relevant.
The structure of the transaction shall be assessed, as appropriate, by reference to the parties involved, its nature, value and characteristics, the work of art or asset concerned, its intended destination, the method of payment and any other relevant circumstances, in order to assess its consistency with the information available and with the client’s stated profile and activities.
Where inconsistencies, unusual circumstances or matters requiring clarification arise, Monterone Art may request such additional information or documentation as may be necessary to obtain a reasonable understanding of the purpose, structure or economic rationale of the transaction.
b) Source of funds and, where applicable, source of wealth
Where relevant, Monterone Art may obtain information concerning the source of the funds used in connection with a relationship or transaction and may request such supporting documentation as may be necessary having regard to its nature, value, structure and level of risk.
Where required by applicable law or justified by a higher level of risk, such checks may extend to the source of wealth of the client or beneficial owner and to other relevant financial circumstances.
The nature and extent of such checks shall be determined on a risk-sensitive and proportionate basis and shall be limited to what is necessary to comply with the applicable obligations.
5 – ENHANCED DUE DILIGENCE AND RISK FACTORS
Monterone Art shall apply enhanced due diligence measures where required by applicable law or where, having regard to the circumstances, a relationship or transaction presents a higher risk of money laundering or terrorist financing. Such measures shall be additional to standard due diligence measures and shall be determined in a manner proportionate to the nature and level of the risk identified.
For these purposes, relevant factors may include, among others, the involvement of structures, parties or intermediaries that increase the complexity of the transaction or reduce its transparency, geographical circumstances, and any other factors which, individually or in combination, give rise to a higher level of risk. Where the client, beneficial owner or any other relevant person is a politically exposed person, a family member or a known close associate within the meaning of applicable law, the enhanced measures required by law shall be applied.
When assessing geographical risk, Monterone Art shall, where relevant, take into account classifications, lists and other sources issued by the European Union, the Financial Action Task Force (FATF) and other competent authorities or bodies. The inclusion of a jurisdiction in any such classification or list shall be assessed in accordance with the legal effects attributed to it under applicable law, and any enhanced measures, restrictions or other actions required by law shall be applied.
The presence of a risk factor shall not, in itself, result in the rejection of a relationship or transaction, unless a prohibition, sanction, restriction or other legal provision prevents it from being carried out. In all other cases, the relevant factor shall be assessed together with the remaining circumstances in order to determine what additional measures, if any, are required.
Where enhanced due diligence is required, Monterone Art may obtain additional or updated information, carry out further checks on the parties involved, beneficial ownership, the purpose or structure of the transaction and the source of funds or, where appropriate, source of wealth, and may intensify ongoing monitoring to the extent necessary to manage the identified risk appropriately.
6 – PAYMENTS AND THIRD-PARTY INVOLVEMENT
a) Payer and source of payment
Where necessary, Monterone Art may verify the identity of the payer, the ownership of the account or payment method used and its connection with the persons involved in the relationship or transaction, as well as, where appropriate, the source of the funds.
Where the payer is not the client, buyer or another principal party to the transaction, Monterone Art may request such explanations or documentation as may be necessary to understand the relationship between them, the reason for the payer’s involvement and the source of the funds, having regard to the circumstances and the level of risk.
Payments must be made using methods permitted under applicable law. Cash payments shall be subject to the limits and requirements established by applicable law.
b) Third-party payments, split payments and refunds
The involvement of a third party in a payment shall not, in itself, result in its rejection, but may give rise to such additional checks as may be necessary to understand its purpose, source and connection with the transaction.
Monterone Art may consider related or structured payments or transactions together where required by applicable law or where their connection is relevant to the assessment of risk. The splitting or structuring of payments shall not prevent the application of any due diligence measures, limits or other requirements arising under applicable law.
Requests for the return or refund of funds, or for changes to their intended destination, may be subject to such checks as are necessary to verify their consistency with the transaction, the identity of the recipient and, where appropriate, the recipient’s relationship with the original payer. Their execution may be made conditional upon completion of any checks required by applicable law.
7 – ONGOING MONITORING AND UPDATING OF INFORMATION
Where an ongoing business relationship exists, Monterone Art shall carry out such monitoring as may be required to ensure that transactions conducted throughout the course of that relationship are consistent with the information available concerning the client, their activities, risk profile and, where appropriate, the source of funds.
The information and documentation obtained in the course of customer due diligence shall be kept up to date to the extent necessary for the proper application of those measures. For these purposes, Monterone Art may request confirmation or updated information and documentation where existing records are no longer current, relevant changes have occurred, or an update is otherwise necessary having regard to the nature and level of risk of the relationship or transaction.
Checks previously carried out may be reviewed or supplemented where circumstances change, inconsistencies arise, or the information available needs to be updated.
The frequency and extent of ongoing monitoring and updates shall be determined on a risk-sensitive and proportionate basis and shall be limited to what is necessary to comply with the applicable obligations.
8 – UNUSUAL TRANSACTIONS AND RESTRICTIONS ON EXECUTION
a) Review of unusual or attempted transactions
Monterone Art shall give particular scrutiny to any facts, transactions or patterns of conduct which, by their nature or circumstances, may be related to money laundering or terrorist financing, irrespective of the amount involved where so required by applicable law.
Particular consideration shall be given, among other matters, to complex or unusual transactions, transactions lacking an apparent economic or lawful purpose, transactions presenting indications of sham arrangements or fraud, and those whose structure or circumstances are not sufficiently consistent with the information available. The existence of an unusual circumstance shall not, in itself, mean that a transaction is unlawful, but shall require it to be examined to the extent appropriate in the circumstances.
Where, following such examination, there are indications or circumstances giving rise to the application of the obligations prescribed by law, Monterone Art shall take the appropriate action and make any required reports or disclosures. Such obligations may also apply to attempted transactions.
b) Non-execution, suspension or termination
Monterone Art shall not establish a business relationship or carry out a transaction where it is unable to satisfactorily apply the customer due diligence measures required by law. Where such inability arises in the course of an existing business relationship, Monterone Art shall take the measures required in the circumstances, including termination of the relationship where legally required.
The processing of a transaction may be suspended while the necessary checks are completed. Where the law requires Monterone Art to refrain from carrying out a transaction, it shall not proceed with that transaction, without prejudice to any exceptions or further actions provided for under applicable law.
c) Confidentiality
Actions and measures undertaken in connection with the prevention of money laundering and terrorist financing shall be subject to the confidentiality and non-disclosure obligations established by applicable law.
In particular, Monterone Art shall not disclose to the client or to any third party that a report or disclosure has been made to the competent authority, or that a transaction is being or may be examined in connection with possible money laundering or terrorist financing, except where such disclosure is permitted by law.
9 – DOCUMENT RETENTION AND COOPERATION WITH THE AUTHORITIES
Monterone Art shall retain the documentation and information obtained or generated in compliance with its anti-money laundering and counter-terrorist financing obligations for the periods and under the conditions prescribed by applicable law.
Where applicable, such records shall include documentation relating to customer due diligence measures, business relationships and transactions, the persons involved, and any analyses or actions carried out, in a manner that enables Monterone Art to demonstrate compliance with the applicable obligations and to reconstruct transactions where necessary.
Documentation shall be retained in a manner that ensures its proper management, integrity, traceability and availability, subject to the access restrictions and other safeguards required by law. The processing of personal data associated with these activities shall also be governed by Monterone Art’s Privacy Policy and by applicable data protection law.
Monterone Art shall provide the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC), as well as any other competent authorities, with such documentation and information as must be provided in the exercise of their respective powers, and shall comply with any requests received within the terms and time limits established by law.
10 – AMENDMENTS AND CONTACT
Monterone Art may amend this Policy to reflect legislative or regulatory changes, guidance or requirements issued by competent authorities, or developments in its activities and transactions.
Any amendments shall be published on the Website and shall apply from the date specified in the relevant version, without prejudice to any additional notices or communications that may be required by law.
Any queries or communications relating to this Policy may be addressed to Monterone Art using the contact details provided on the Website.
Monterone Art’s responses and communications shall, where applicable, be subject to the duties of confidentiality and non-disclosure, and to any other restrictions established by applicable law.
