How Nominated Officers and Deputies can ‘second’ their reports.
Our priority is to help you comply.
Indeed when getting it wrong can be costly - be that losing a client, fines or prosecution - we believe you should be able to rely on us to help you make the right decisions and get this AML business right.
As we continue to follow updates to Regulation - as reflected in the Guidance document published by the British Art Market Federation - new requirements continue to emerge and these are continually being reflected in the support you receive, the articles available and may include enhancements to the platform.
As part of your obligations, your Due Diligence and AML processes will fall under the remit of the Nominated Officer, while their duties are supported by a Deputy.
If you have yet to determine who will be your Deputy you should make this a priority as this is required. To learn more about why this is important, please view the corresponding article on this page.
In this short video, we’re going to explore the Notes & Comments feature and how and why Nominated Officers and Deputies should be working together to ‘second’ the decision making you’re required to document in your reports.
Notes and Comments are available on each of your reports.
Here’s a Due Diligence report that was created and approved some weeks earlier by the Nominated Officer. As we scroll down we can see notes and comments for the due diligence report.
Comments are date and time stamped and display the name of the member of the team who documented the decision.
We can see the initial report was approved by the Deputy and later that same day the Nominated Officer also reviewed the report and ‘seconded’ the Deputy’s actions.
Today, the same client is purchasing another work. While there is no cause to carry out due diligence again, we must document that we can confirm that our clients' circumstances haven’t changed in order to upload our obligation to monitor our ongoing relationships.
The Deputy leaves a comment to that effect.
If you’d like to learn more, or would like to create an account for a Deputy or other member of your team get in touch.