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The Art Industry and U.S. Policies that Undermine Sanctions/Section 2E

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by the Permanent Subcommittee on Investigations
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​E. Voluntary Anti-Money Laundering and Sanctions Programs in the Art Industry

As explained earlier, under current U.S. law, the art industry is not legally required to comply with the same anti-money laundering requirements as certain financial institutions listed in the BSA.[1] The BSA authorizes the Treasury Secretary to require those financial institutions to file "certain reports or records. where they have a high degree of usefulness in criminal, tax, or regulatory investigations or proceedings, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism."[2] In addition, the BSA states that "in order to guard against money laundering through financial institutions, each financial institution shall establish anti-money laundering programs, including, at a minimum—

  1. the development of internal policies procedures, and controls;
  2. the designation of a compliance officer;
  3. an ongoing employee training program; and
  4. an independent audit function to test programs."[3]

Although the provisions of the BSA do not apply to the art industry, all U.S. citizens and companies must comply with U.S. sanctions programs.[4] Under IEEPA for example, any U.S. citizen or entity that conducts business with a person on the SDN list is subject to criminal and civil liability.[5]

​Despite not having a legal obligation to implement AML programs under the BSA, the Subcommittee found that the four biggest art auction houses described above all have voluntary AML programs in place. In addition, all four have sanctions compliance programs. This section details the voluntary AML and sanctions programs in place at: (1) Sotheby's; (2) Christie's; (3) Phillips; and (4) Bonhams. The Subcommittee also interviewed one private art dealer who admitted they operated with no AML or sanctions compliance programs in effect.

1. Sotheby's

Sotheby's informed the Subcommittee that it has a compliance department that oversees all issues relating to money laundering, terrorist financing, tax evasion, sanctions policies, and related litigation.[6]

Worldwide Policy on Money Laundering, Terrorist Financing and Tax Evasion. Sotheby's has a detailed, written set of rules to combat money laundering, terrorist financing, and tax evasion. The current policy document (the "2018 AML Policy") "applies to all members of the Board of Directors, employees, consultants, independent contractors, and others providing services to Sotheby's."[7] The document also states that "Sotheby's is committed to strict compliance with all applicable laws regarding anti-money laundering, combatting terrorist financing, and tax evasion."[8] It further states that "if you have any concerns about the activity of a client or legality of a transaction in which Sotheby's is involved you must raise those concerns with the Compliance Department immediately."[9]

The 2018 AML Policy explains that "the single most effective tool in combatting money laundering or terrorist financing is to have adequate knowledge about our clients. We must know who our clients are regardless of whether they are new or existing clients, occasional or regular purchasers or consignors and the volume or value of the transaction activity."[10] The 2018 AML Policy explains that "for all clients, new or existing, we must: (a) know the true identity of the person or entity who owns the property or funds in question; and (b) understand the source of the client's funds."[11] The 2018 AML Policy also outlines how to deal with an agent acting on behalf of an undisclosed principal. The document states, in pertinent part: ​

In the context of ordinary auction and private sale transactions with an agent who you know or believe is acting on behalf of a principal whose identity is not disclosed, we must treat the agent as our client for the purposes of customer due diligence and verification of identification. Before you engage in transactions with agents for undisclosed owners, (e.g., dealers who wish to keep the names of their clients confidential from us), you must ensure that we know and trust the agent concerned . . . In addition, you should confirm that the agent knows personally and/or has conducted appropriate due diligence on its clients' identities and activities.[12]

The 2018 AML Policy also notes "certain clients and transactions by their nature pose a higher risk of money laundering/terrorist financing or tax evasion. You must consider the below risk factors in connection with every transaction, and if you believe that your client falls within any of the following categories you must notify the Compliance Department immediately."[13] The "higher risk indicators" include: "clients residing in or with property/funds sourced from high-risk jurisdictions, which are those jurisdictions listed in Annex B."[14] Annex B lists 38 countries, including Russia.[15] Sotheby's added Russia to the list of high-risk jurisdictions in 2018; Russia was not included as a high-risk jurisdiction in its prior AML policy.[16]

The 2018 AML Policy also requires enhanced due diligence for transactions involving a politically exposed person or "PEP."[17] A PEP is defined in the 2018 AML Policy as "an individual that is, or has, at any time in the preceding year been entrusted with a prominent public function by any state, a European Community institution (such as the European Commission) or an international body . . ."[18] The definition of PEP also includes immediate family members and any "person known to be a close associate of the PEP (such as a person who is in a close business relationship with a PEP or a trust or company formed for the benefit of a PEP)."[19] The 2018 AML Policy explains that for PEPS "the risk of money laundering is legally presumed to be higher based on his/her position and the greater likelihood that he/she will be exposed to corruption."[20]

​The Sotheby's 2018 AML Policy also lists various types of "activity which may cause concern," which it refers to as "red-flags."[21] The 2018 AML Policy states that "Sotheby's may not establish or maintain a business relationship or conclude a transaction with a client if at the time we are suspicious about money laundering, terrorist funding, the client, the source of funds or the property or that the transaction is part of tax evasion."[22] The 2018 AML Policy lists a number of different types of "red-flags," including, but not limited to the following:

  • Client is unwilling to present requested identification documents, even after we have given the client reasonable explanations as to why we have asked for this information.
  • Client refuses to provide complete and accurate contact information or business affiliations.
  • Client gives evasive or incomplete answers to basic, routine questions.[23]

The 2018 AML Policy states that "all employees are required to report any suspicious transactions or suspected fraud to the Compliance Department."[24] Worldwide Policy on Compliance with Economic Sanctions Programs. Sotheby's 2016 Worldwide Policy Regarding Compliance with Economic Sanctions Programs (the "2016 Sanctions Policy") establishes that "no Sotheby's employee, wherever located, may transact with any blocked party."[25] The 2016 Sanctions Policy explains that OFAC:

administers and enforces U.S. economic and trade sanctions against targeted foreign countries, terrorists and terrorism-sponsoring organizations, international narcotics traffickers, and others. The regulations and executive orders administered and enforced by OFAC prohibit, among other things, the engagement by U.S. persons in transactions with, or the provision by U.S. persons of services to, certain entities and individuals on the Specifically Designated Nationals and other Blocked Persons List and other OFAC lists (collectively, the "OFAC Lists").[26]

The 2016 Sanctions Policy also states, "Sotheby's must ensure that no actual or potential client, no agent or intermediary, no beneficiary or principal whose name it acquires in the ordinary course of business . . . are named on the OFAC Lists, are owned 50 percent or more by one or more persons on the OFAC Lists, or any other ​relevant Blocked Parties list."[27] The document instructs Sotheby's employees to contact the Compliance Department if they "believe that an active Sotheby's client is listed on any relevant Blocked Parties lists."[28]

Sotheby's also "conducts regular screening through an automated tool to ensure that no counterparty is on any relevant Blocked parties list. Sotheby's also reruns the filter against its counterparties following the release of updates to the OFAC Lists and other relevant lists."[29] This process is monitored by the Compliance Department.[30] Sotheby's Compliance Department also conducts due diligence on individual transactions and requires contractual clauses and representations from consignors and purchasers to ensure that such purchases are consistent with Sotheby's compliance requirements and that the real party in interest is not subject to U.S. prohibitions.

Sotheby's Briefing. On October 25, 2018, senior employees from the Sotheby's Compliance Department briefed Subcommittee staff on the company's policies and practices. The briefing was led by Sotheby's former Chief Global Compliance Counsel, Head of Regulatory Affairs ("Chief Compliance Counsel").[31] She explained to the Subcommittee that while the art industry is not technically regulated, many regulatory environments apply to the art business.[32] She continued that Sotheby's has a "mature and well-developed" AML and sanctions compliance program, in which employees use a risk-based approach.[33] She said the higher the value of the art transaction, the more Sotheby's needs to understand about the background of the client or the ability of the client to purchase the item.[34]

The Chief Compliance Counsel explained that, in some cases, dealers will purchase a work of art and may subsequently sell it to another person.[35] In those instances, she stated that Sotheby's "doesn't have a way to get that information" about the person to whom the dealer may subsequently sell the artwork.[36] She stated that, at times, Sotheby's has asked dealers on whose behalf they are purchasing an item, but there is an economic disincentive for dealers to provide that information to Sotheby's.[37] The dealers believe that if Sotheby's knew the identity of their clients, Sotheby's would go straight to their client and cut out the dealer. ​The art dealer's livelihood depends on protecting client information.[38] Should Sotheby's ask a dealer to whom they may intend to resell the artwork following the dealer's transaction with Sotheby's, according to the Chief Compliance Counsel, the dealer would respond, "Are you kidding me? I'm not telling you."[39]

Ultimately, according to the Chief Compliance Counsel, whether to continue and execute a transaction with a dealer who may sell to a subsequent buyer was a judgment call.[40] If the dealer is someone Sotheby's knows; established in the art world; someone Sotheby's has transacted with many times in the past; and is not under investigation, she said Sotheby's is likely to complete the transaction.[41] If the dealer does not meet those criteria, she said Sotheby's would refuse to move forward: "we'll say there's too much smoke here, and we've done that."[42]

The Chief Compliance Counsel stated that in some instances, the Compliance Department offers its counterparties the option of telling Sotheby's Compliance personnel who their principal is, which enhances Sotheby's ability to perform its due diligence and allows counterparties to protect their commercially proprietary information. Sotheby's has been successful in this way in encouraging intermediaries to divulge their clients' identities without risk of losing their business portfolio.[43] She said that Sotheby's "has a lot of success with that," yet some intermediaries still refuse to disclose their principal due to a lack of trust.[44] Sometimes intermediaries request before disclosing the identity of their principal a non-disclosure agreement ("NDA") to provide comfort that Sotheby's would not share the information outside of its Compliance Department.[45]

The Chief Compliance Counsel also discussed Sotheby's sanctions compliance policies.[46] She explained that Sotheby's runs its client list through World-Check on a daily basis to identify possible sanctions violations.[47] This check includes "all the major sanctions from around the world."[48] Any hits on sanctioned entities get flagged to the Compliance Department.[49] For private sales, Sotheby's runs the names for both the buyer and the seller through World-Check to determine if either are sanctioned.[50] World-Check is a database used by financial institutions to ​identify PEPs, SDNs, and other high-risk individuals and organizations.[51] She told the Subcommittee that Sotheby's "has never transacted with an SDN or blocked person."[52] She asserted the company has "never had a hit and never inadvertently transacted with one."[53]

The Chief Compliance Counsel also explained that Sotheby's due diligence at the time associated with the Subcommittee's review into a new client or transaction involved a risk-based analysis, which factored in the value of the transaction, the profile on the person, and the legitimacy of why the person has the artwork or the funds to purchase the artwork.[54] At the time, Sotheby's was aware of the risk that the buyer may not be the UBO and dealt with that risk by reviewing the information to which it had access and kept an eye out for red flags.[55] She noted there is a significant competitive advantage in the art world to having information about who owns what art, and intermediaries in the art world frequently do not want to disclose who their clients are because they do not want to be cut out of the deal.[56] At the relevant time, Sotheby's trusted some clients to do their own KYC of their transactions parties. And Sotheby's will walk away from a deal if it was not comfortable with the responses it received.[57]

2. Christie's

Global Anti-Money Laundering and Anti-Terrorist Financing Policy. Christie's first established an AML policy in December 2008,[58] and updated it in 2014 and 2015,[59] The current AML policy was updated and finalized in March 2018 (the "2018 AML Policy").[60] Christie's former Global Head of Compliance in London explained that the AML policy matured over the years.[61]

The 2018 AML Policy established know your client (or "KYC") procedures as a "key component of Christie's AML Policy. This involves collecting, verifying and keeping records of the identity of all clients."[62] The document states that "Christie's will request sufficient identification documentation from clients to verify their identity using a risk-based approach. Where there is a greater perceived risk ​of money laundering or terrorist financing, enhanced due diligence, client risk reviews and KYC checks may be required."[63] The 2018 AML Policy poses two questions for Christie's employees to consider regarding KYC procedures:

  • Am I satisfied that the person/entity I am dealing with is the person/entity they claim to be?
  • Do the circumstances of the proposed transaction give rise to a suspicion that the property being sold or funds used for payment are derived from criminal activity or may be used to fund terrorism?[64]

The 2018 AML Policy also states "for clients who are legal entities, Christie's must also identify the natural persons in control (e.g., directors and beneficial owners)."[65] Christie's requires certain forms of identification for individuals making purchases or the beneficial owner of a private company, including offshore entities.[66]

Christie's also notes circumstances that are considered "red flags."[67] The document explains that red flags "are indicators of circumstances where [Christie's] may require further information from or about the client" and provides specific examples.[68]

Sanctions Policy. The current Christie's sanctions policy was issued on May 1, 2018.[69] It states that "Christie's is committed to complying with all Sanctions that may apply to its business at any given time."[70] As such, employees and representatives must not "enter into or facilitate any business, dealings, or other activities, directly or indirectly, involving or for the benefit of Sanctioned Parties, except where expressly approved in writing by Compliance."[71]

The Christie's Sanctions Policy delineates certain countries as high risk countries and requires "all potential business and relationships with clients, suppliers and other third parties in High Risk Countries [to] be referred to Compliance prior to any business being conducted or any business relationship being established."[72] The policy also states that "Christie's will ensure that employees in specific regions and departments exposed to dealings with High Risk Countries received appropriate training on Christie's Sanctions obligations."[73]

​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").[74] According to her, the Legal Department acts as a "helicopter parent," serving as an independent check on Christie's business activities.[75] 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."[76] The Legal function serves as "an independent check away from the business to look at all decision being made" to ensure appropriate compliance.[77] The Compliance Manager for the Americas added that there are "conversations between [client-facing] front line staff to alert [Legal] to red flags."[78] He continued that "if a client gives [client-facing staff] pushback it would be an immediate escalation to Legal."[79] Regarding Christie's AML policies, Christie's General Counsel noted that they are applicable to all Christie's employees globally.[80] Additionally, all Christie's employees receive training on the policies.[81]

Christie's General Counsel noted that the Legal Department has the ability to "restrict" clients—such as sanctioned individuals.[82] Restricting a client "blocks" them globally from transacting with Christie's.[83] Only the Legal Department is able to place or remove these restrictions.[84] 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.[85] If information is less clear, the decision is escalated to the head of the compliance department through a report.[86] If necessary, the issue can subsequently be escalated to the General Counsel in London or further to the Deputy CEO for a decision.[87]

​3. Phillips

Worldwide Anti-Money Laundering Policy. Phillips provided the Subcommittee with its AML policy (the "Phillips Policy"), which stated that Phillips employees "must report any knowledge or suspicion to the appropriate Phillips Anti-Money Laundering Officer, who then decides whether to make a report to the relevant authority."[88] The Phillips Policy first asks employees to require new clients to submit certain forms of government-issued identification.[89] The Phillips Policy also notes that "key questions to ask include:

  • Is the consignor or buyer reluctant to provide personal information?
  • Is there any suggestion that the client is evading, has evaded or will evade taxes?
  • Who is the beneficial owner of the property if it is consigned by an off-shore company?"[90]

The Phillips Policy also includes a section entitled "Red Flags," which explains "if any of the following 'Red Flags' appear and there is no reasonable explanation for the particular Red Flag such that the employee is concerned about the client or transaction, the matter MUST be referred immediately in writing and by telephone to the appropriate Anti-Money Laundering Officer."[91] The Phillips Policy continues with a list of "what to look for," such as:

  • Client provides unusual, inconsistent, or suspicious identification; and
  • Clients from certain high risk jurisdictions, particularly if wanting to pay from a local bank (e.g., Iran, North Korea, Algeria, Myanmar, Syria, Indonesia, Yemen).[92]

While the Phillips Policy did not include instructions regarding compliance with sanctions, Counsel for Phillips explained that sanctions compliance was considered a component of Phillips anti-money laundering compliance program, noting Phillips' compliance training from as early as 2011 covered risks and compliance protocols related to sanctions.[93]

Phillips Briefing. Subcommittee staff received a briefing from Phillips General Counsel based in London.[94] He explained that the company's policies have developed over time.[95] He stated that Phillips generally followed what the rest of ​the art industry was doing with regard to AML policy.[96] Looking forward, he noted that Phillips was working on incremental steps towards a better policy-based on some of the same obligations imposed on banks regarding enhanced customer due diligence.[97] He said he believes this will lead to increased transparency from clients.[98] As such, Phillips' General Counsel stated he believed clients will not be surprised when Phillips begins asking for additional due diligence information, including ultimate beneficial owner information.[99]

Anti-Money Laundering, Sanctions & Counter-terrorism Financing Policy. Phillips' General Counsel also explained to the Subcommittee that in late 2018, Phillips was preparing to update its AML policy.[100] The current policy was issued on November 6, 2018 and included instructions on: Money Laundering; Sanctions; Due Diligence Process; Frequently Asked Questions; and Client Identification Checklist and Screening Requirements.[101] Counsel for Phillips stated "the issuance of the policy was then followed by mandatory training in all sale sites in 2018 for all staff."[102] Phillips' counsel continued:

Phillips currently screens all sellers and buyers—whether existing or new against sanctions databases. In addition, [art] agents are required to identify their principal and provide Phillips with KYC documentation in relation to themselves and their principal. Phillips insists upon ultimate beneficial ownership (UBO) information for all companies and does not rely upon third parties to carry out KYC—it is all handled in house. Phillips does not pay out to sellers and does not issue invoices to buyers without having full KYC documentation.[103]

4. Bonhams

Summary Controls & Procedures Manual. In April 2018, Bonhams U.S. issued its Bonhams U.S. Group Summary Controls & Procedures Manual (the "2018 Bonhams Manual") to ensure "that Bonhams and our stakeholders reduce the risk of fraudulent transactions and are compliant with all appropriate regulatory and taxation requirements."[104] The 2018 Bonhams Manual explained that the company would employ "a risk-based approach to AML [that] involves assigning differentcategories of risk (e.g. low, medium, high) to various types of client [s]. We have ​adopted such an approach, giving particular regard to our circumstances, such as our commercial activity, our range of clients and the registration process."[105] The 2018 Bonhams Manual identifies the following risk areas:

Type of client—Is the client a private individual or corporate entity? Is the client acting as a principal or agent? Are they an existing or new client? Are you visiting the client in their home or are you seeing them for the first time when they have walked in off the street?

Type of customer—Is the customer present at the sale? Does the customer mix business and private transactions?

Geographical—Where is the client situated?

Transaction/Payment type—How does the buyer settle his/her invoices? How is the vendor paid?

Ongoing monitoring (Behavior) & other risk factors

  • Is the transaction consistent with the client's payment history?
  • Is there any unusual or erratic behavior displayed by the client?
  • Are there any indicators that raise concerns that the transaction is suspicious?
  • A combination of the various criteria should help determine the client's risk category?[106]

The 2018 Bonhams Manual continues:

However, it is ultimately the member of staff's professional judgment that will determine whether a client or particular transaction requires further examination.

The higher the risk level of the client, the more scrutiny should be applied before entering into business relations with a client. If it doesn't "Smell" right, tell us![107]

The 2018 Bonhams Manual also requires that a vendor provide identification. Further, an "agent as consignor . . . should disclose to [Bonhams] who their 'principal' is (especially if that person is not signing the contract) in . . . the Master Consignment Agreement (MCA) before the agent signs."[108] The document continues: "Bonhams should request or seek confirmation of agency or representation relationship (as ​between the agent and principal) either by confirming with the principal or requesting documentary support thereof from the agent."[109]

Bonhams Briefing. In a briefing with Subcommittee staff, Bonhams U.S. Counsel, along with outside counsel, explained that prior to the 2018 Bonhams Manual, Bonhams U.S. counsel communicated AML policies to staff during briefings and trainings.[110] Bonhams U.S. Counsel noted that until 2016, most of the Bonhams U.S. staff was based in San Francisco, which made communication much easier.[111] She said there was not a need for PowerPoint presentations on AML compliance because "everyone was sitting around the same desk.[112]"

Bonhams U.S. Counsel told the Subcommittee that, historically, Bonhams U.S. did not check its clients against OFAC's SDN list or any other sanctions lists.[113] Rather, Bonhams U.S. relied on AML and sanctions checks that its financial institutions perform.[114] According to Bonhams U.S. Counsel, the company would not knowingly engage in transactions with family members of sanctioned individuals.[115] Additionally, she represented that Bonhams U.S. would not conduct business with art agents or advisors who were known to represent sanctioned individuals.[116]

5. Private Art Dealer

The Subcommittee also investigated private art sales, as further explained below. In reviewing those transactions, the Subcommittee interviewed a private art dealer based in New York (the "Private Dealer").[117] The Private Dealer has thirty years of experience in the art market, having studied at major universities and worked at many art galleries and major art auction houses

The Private Dealer explained that, at the time the transaction described below took place, she had no written AML or sanctions policies.[118] The Private Dealer explained that she had not received any AML or sanctions-related training at any of the galleries or art auction houses at which she previously worked.[119] When asked whether she had a legal obligation to question the origin of the funds ​used to purchase a piece of art, the Private Dealer responded that she did not.[120] She explained that in the art industry, questioning the source of funds would be considered contrary to industry standards and norms at the time—although she has done it on occasion—and that art agents and intermediaries would not want to provide that information because of confidentiality and privacy concerns of both the art agents and intermediaries and their clients.[121] She noted, however, that most of her clients are American and that she knows the identity of the ultimate buyer in the "majority" of her transactions.[122]

The Private Dealer explained that over the years, her practices regarding AML have significantly changed, but since the art industry is not regulated in the United States, she has had to self-regulate, rely on the advice of lawyers with expertise in AML and other related areas, and look for potential red flags in transactions, including with respect to the provenance of art pieces, in addition to relying on her gut.[123] To that end, she said that if something does not feel right, or she does not know someone personally or through their reputation, she will not do business with them.[124]

  1. ↑ For the complete list of entities that fall under the definition of a "financial institution" and therefore must comply with the Bank Secrecy Act, see 31 U.S.C. § 5312 (a)(2).
  2. ↑ 31 U.S.C. § 5311.
  3. ↑ 31 U.S.C. § 5318(h)(1)(A)-(D).
  4. ↑ 50 U.S.C. § 1705(a).
  5. ↑ 50 U.S.C. § 1705(b)-(c).
  6. ↑ Subcommittee Briefing with Sotheby's Employees (Oct. 25, 2018).
  7. ↑ SOT-000054-78.
  8. ↑ Id.
  9. ↑ Id.
  10. ↑ Id.
  11. ↑ Id. (emphasis in original).
  12. ↑ Id.
  13. ↑ Id.
  14. ↑ Id.
  15. ↑ Id.
  16. ↑ SOT-000419-43.
  17. ↑ SOT-000054-78.
  18. ↑ Id.
  19. ↑ Id.
  20. ↑ Id.
  21. ↑ Id.
  22. ↑ Id.
  23. ↑ Id.
  24. ↑ Id. (emphasis in original).
  25. ↑ SOT-000104-114.
  26. ↑ Id.
  27. ↑ Id.
  28. ↑ Id.
  29. ↑ Id.
  30. ↑ Id.
  31. ↑ Subcommittee Briefing with Sotheby's Employees (Oct. 25, 2018).
  32. ↑ Id.
  33. ↑ Id.
  34. ↑ Id.
  35. ↑ Id.
  36. ↑ Id.
  37. ↑ Id.
  38. ↑ Id.
  39. ↑ Id.
  40. ↑ Id.
  41. ↑ Id.
  42. ↑ Id.
  43. ↑ Id.
  44. ↑ Id.
  45. ↑ Id.
  46. ↑ Id.
  47. ↑ Id.
  48. ↑ Id.
  49. ↑ Id.
  50. ↑ Id.
  51. ↑ See Refinitiv World-Check Risk Intelligence, Refinitiv, https://www.refinitiv.com/en/products/world-check-kyc-screening.
  52. ↑ Subcommittee Briefing with Sotheby's Employees (Oct. 25, 2018).
  53. ↑ Id.
  54. ↑ Id.
  55. ↑ Id.
  56. ↑ Id.
  57. ↑ Id.
  58. ↑ Christies-PSI-00000286-89.
  59. ↑ Christies-PSI-00000294-99 (2014); Christies-PSI-00000300-05 (2015).
  60. ↑ Christies-PSI-00000001-006.
  61. ↑ Subcommittee interview of Christie's former Global Head of Compliance (Jul. 15, 2019) (also referred to below as Christie's "Compliance Counsel").
  62. ↑ Christies-PSI-00000001-006.
  63. ↑ Id.
  64. ↑ Id.
  65. ↑ Id.
  66. ↑ Christies-PSI-00000009-13.
  67. ↑ Christies-PSI-00000324-26.
  68. ↑ Id.
  69. ↑ Christies-PSI-00000014-19.
  70. ↑ Id.
  71. ↑ Id.
  72. ↑ Id.
  73. ↑ Id.
  74. ↑ Subcommittee Briefing with Christie's Employees (Feb. 8, 2019).
  75. ↑ Id.
  76. ↑ Id.
  77. ↑ Id.
  78. ↑ Id.
  79. ↑ Id.
  80. ↑ Id.
  81. ↑ Id.
  82. ↑ Id.
  83. ↑ Id.
  84. ↑ Id.
  85. ↑ Id.
  86. ↑ Id.
  87. ↑ Id.
  88. ↑ PHILLIPS-00401-04.
  89. ↑ Id.
  90. ↑ Id.
  91. ↑ Id. (emphasis in original).
  92. ↑ Id.
  93. ↑ See Letter from Counsel for Phillips to Subcommittee staff (Jul. 22, 2020).
  94. ↑ Subcommittee Briefing with General Counsel for Phillips (Dec. 11, 2018).
  95. ↑ Id.
  96. ↑ Id.
  97. ↑ Id.
  98. ↑ Id.
  99. ↑ Id.
  100. ↑ Id.
  101. ↑ Draft Phillips Anti-money Laundering, Sanctions & Counter-terrorism Financing Policy provided to the Subcommittee; Email from Counsel for Phillips to Subcommittee staff (Mar. 19, 2020).
  102. ↑ Email from Counsel for Phillips to Subcommittee staff (Mar. 19, 2020).
  103. ↑ Id.
  104. ↑ BON004674-4700.
  105. ↑ Id.
  106. ↑ Id.
  107. ↑ Id.
  108. ↑ Id.
  109. ↑ Id.
  110. ↑ Subcommittee Briefing with Bonhams U.S Counsel (Feb. 22, 2019).
  111. ↑ Id.
  112. ↑ Id.
  113. ↑ Id. Bonhams reported that it now routinely screens all clients against the SDN and other sanctions list via a third party screening provider.
  114. ↑ Id.
  115. ↑ Id.
  116. ↑ Id.
  117. ↑ Subcommittee interview of Private Dealer (Sept. 7, 2018).
  118. ↑ Id.
  119. ↑ Id.
  120. ↑ Id.
  121. ↑ Id.
  122. ↑ Id.
  123. ↑ Id.
  124. ↑ Id.
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