This Anti-Money Laundering Policy (hereinafter referred
to as “Policy”) sets out the general rules and procedures followed by ArtHub on
the implementation of procedures in accordance with the relevant Anti-Money
Laundering laws, rules and regulations (hereinafter referred to as “AML”).
The terms “We”, “Our”, “Company” and “Us” refer to ArtHub.
The terms “User”, “You” and “Your” refer to users (Customer and Vendors) of our
website.
This Policy is part of ArtHub’s commitment in
participating in international efforts to counter money laundering and
terrorism financing.
This Policy applies uniformly to any User (Customers
and Vendors) that wishes to use the services offered by or otherwise benefit
from the use of our website. Therefore, each User that visits the ArtHub
website must carefully read and comply with this Policy. If any User does not
agree with this Policy or any part of it, then such User must refrain from
accessing and using the website and/or the services offered by the website.
ArtHub reserves the right to modify or amend this
Policy at its sole discretion. Any revisions to this AML Policy will be posted
on our website. If we make changes, we will notify you by revising the date at
the top of this Policy. We strongly recommend you to periodically visit the
website to review any changes that may be made to this Policy to stay updated
on our AML practices. Your continued usage of the website and/or services shall
mean your acceptance of those amendments.
This Policy is a part of and is to be read along
with our Terms and Conditions
and Privacy Policy.
You may view the current version of these policies on our website.
Due Diligence and Know Your Customer Procedures
1. You may either at the time of registering as a
User or upon execution of any payment transactions and/or any other form of
transaction available through our website and generally when using the services
offered by our website or periodically for purposes of updating records and
on-going due-diligence procedures under AML laws and regulations, be required
to take part in the User identification and verification process. For this
purpose, we will follow the procedure prescribed under this Policy.
2. As part of our User identification and
verification process we may collect the following information, but ArtHub
reserves the right to request any additional information:
• Individual Users: Name, Date Of Birth, Email
Address, Phone Number and Residential Address, copies or certified copy of
passport/identity card, documents pertaining to business/financial status of
such User;
• Business Users: Business name, name, contact-details,
and copy of passport/identity card of the authorized representative, one
certified copy each of the certificate of incorporation, memorandum and
articles of association/partnership deed (as the case may be), board resolution
and/or other authorization documents giving authority to the representative
chosen to execute transactions on the website.
• Additional Information from Business Users: If the
User is a legal entity, the Beneficial Owner of such entity must be identified
and you must also assist in the verification of the identity of such Beneficial
Owner and any individual who purports to act on behalf of such legal entities.
3. You must promptly update us of any changes to the
customer information provided to us within five (5) days of effecting such
changes.
4. ArtHub reserves the right to refuse registration
to, or to bar transactions from or to, or terminate any relationship with, any
customer for any reason (or for no reason) at any time. Without limiting the
generality of the foregoing, this includes, but is not limited to, anyone from
or in jurisdictions that do not meet international AML standards, anyone that
is a Politically Exposed Person (“PEP”) within the meaning of the AML laws and
regulations, anyone on an official, governmental or intergovernmental Sanction
Lists, upon reasonable request or direction of a competent enforcement
authority, or, anyone that fails to meet any customer due diligence standards,
requests, or requirements of ArtHub.
5. If we believe any information obtained from the
User hereunder is (a) inadequate or incomplete; (b) false or misleading; (c)
insufficient resulting in an inability to readily verify the same; (d)
appearing on any Sanctions Lists; or e) result in suspicious activity, we may
in our sole discretion either refuse or terminate the registration of such
account or require such User to verify the documents submitted by it again. We
may also, in our sole discretion, refuse to open any new accounts, terminate
existing User accounts after giving due notice, or refuse to process any
transactions on the website if we are unable to verify any information due to non-cooperation
by the User, or if such transactions are likely to have a material adverse
effect on us for being in violation of any applicable laws or industry
best-practice guidelines.
Third Party Service Provider
We may, at our sole discretion, at the time of the
User registration process, request one or more appropriate third-party service
provider to assist us in the authentication and verification of the documents
provided by you. We also reserve the right to verify customer identity through
non-documentary means or both. We may also use non-documentary means if we are
still uncertain about whether we know the true identity of a User. We will use
the following non-documentary methods of verifying identity: • Confirming
validity of email; • Confirming validity of telephone number or bank account
number; and • Confirming your location using, among others, your IP address.
Suspicious Activity
1. All transactions of which the amounts involved
exceed the limits specified by local or applicable laws and industry best
practices will be monitored, flagged for review and if necessary, reported to
our Compliance Officer.
2. In addition to the above, we may regularly
monitor all transactions executed and/or attempted to be executed on our
website, in order to promptly identify any suspicious activity, that may
include, but not limited to, the following: • customer is reluctant to provide
details of his/her identity; • customer is trying to use intermediaries to hide
its identity or involvement in the transaction; • there appears to be no
genuine reason for the customer using the services of ArtHub; • money is paid
by a third party who does not appear to be connected with the customer; • the
customer requests payment to be made to a third party who has no apparent
connection with the customer; • activity that appears to be unusual due to the
reason of being inconsistent with any User’s risk profile, expected usage
pattern or sophistication.
Record Keeping
Records of all transactions executed by the User on
our website, are kept for a period of at least 5 (five) years from the date of
their completion. Additionally, copies or references to the evidence obtained
of a customer’s identity are maintained for five years after the end of the
customer relationship, or five years from the date when the transaction was
completed.
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