Christie's Briefing. Employees from Christie's U.S.-based legal department in New York briefed Subcommittee staff on Christie's anti-money laundering policies and sanctions compliance, led by Christie's General Counsel for Dispute Resolution and Legal Public Affairs ("Christie's General Counsel").[1] According to her, the Legal Department acts as a "helicopter parent," serving as an independent check on Christie's business activities.[2] She noted that the AML policy applies to all employees, including client-facing employees, because Christie's "wants [all employees] to know they are responsible for [compliance] issues."[3] The Legal function serves as "an independent check away from the business to look at all decision being made" to ensure appropriate compliance.[4] The Compliance Manager for the Americas added that there are "conversations between [client-facing] front line staff to alert [Legal] to red flags."[5] He continued that "if a client gives [client-facing staff] pushback it would be an immediate escalation to Legal."[6] Regarding Christie's AML policies, Christie's General Counsel noted that they are applicable to all Christie's employees globally.[7] Additionally, all Christie's employees receive training on the policies.[8]
Christie's General Counsel noted that the Legal Department has the ability to "restrict" clients—such as sanctioned individuals.[9] Restricting a client "blocks" them globally from transacting with Christie's.[10] Only the Legal Department is able to place or remove these restrictions.[11] The decision to restrict someone with derogatory information is simple; the Legal Department can simply say "no" and restrict that individual from transacting with Christie's.[12] If information is less clear, the decision is escalated to the head of the compliance department through a report.[13] If necessary, the issue can subsequently be escalated to the General Counsel in London or further to the Deputy CEO for a decision.[14]
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