Gavel and Passport

Identity and Anti Money Laundering Regulations


From 10 January 2020, art market participants such as Gildings Auctioneers, who deal in sales, purchases and/or storage of "works of art" with a value of 10,000 euros or more, will be subject to further anti money-laundering obligations, under the Money Laundering Regulations 2017. These are issued by HMRC and are part of an international effort to tackle anti money laundering globally. As part of these obligations, we have to satisfy ourselves with the identity of our clients, be they vendors or buyers. For that reason, we are asking for all clients to provide proof of identity prior to selling or purchasing items with Gildings Auctioneers. We answer some questions that may stem from this throughout this page - Click to expand each question.

Gildings Auctioneers are a registered Art Market Participant with HMRC. We are legally obliged to identify the person we are dealing with in any transaction (buying or selling) or, when dealing with a corporate body or a trust, the person or persons who control that entity. This is often called Customer Due Diligence, or CDD. In providing your ID documents, we are better able to know our clients and fulfill our obligations as a regulated business. A digital copy shall be retained in strict confidentiality and in compliance with our Privacy Policy.

In order to be a client of Gildings Auctioneers we will need to ascertain the following:

  • Name
  • Residential address
  • Date of birth
  • Photograph on an official document which confirms their identity
  • The purpose of the business relationship – are you selling? Are you buying? Or both?

In order for us to verify this information, we will need to see one of the supporting documents. Accepted photographic ID includes:

  • Valid passport
  • Valid photocard driving licence
  • Firearms certificate or shotgun licence
  • Identity card issued by the Electoral Office for Northern Ireland

Non-photographic ID must be supported with further proof of address. Government issued documents without a photograph includes:

  • Valid (old style) full UK driving licence
  • Instrument of a court appointment (such as liquidator or grant of probate)
  • Current council tax demand letter or statement

Examples of other documents to support proof of address includes:

  • Current bank statements (within the last three months)
  • Credit/debit card statement (within the last three months)
  • Utility bills (within the last three months)

Ideally, we would verify the original forms of ID in person at the saleroom address. We will not accept copies of documents, they must be the originals. We shall then take digital copies and securely store them in compliance with our Privacy policy.

Alternatively, clients can securely upload digital formats (pdf or jpg files) via our website directly to their personal Gildings account. To register for an account click HERE.

Or we may send you an email with a secure link to upload documents to us via a third-party partner – Trust ID.

If you have a Gildings account you can log in and securely upload your own ID documents to your account. Once logged in, go to 'My Account' and then 'Identity Documents' where you will have a drop-down option for Type and then a File Select filed to search for the file you wish to upload on your computer. You can upload JPG or PDF files, but smaller than 2MB. The below is a sample screenshot of where to find this facility:

Screenshot ID


We store digital copies of the documents on our database in association with your account. We use the information on the documents to verify the information you have registered with us. We may then perform ID checks through our third-party partner Trust ID to further verify the documents. We shall record a document’s expiry date (if applicable) and shall ask you for an updated copy once that date has passed.

Yes, all clients, old or new, will need to provide copies of the ID to continue our business relationship. This may be regarded an inconvenience but we only need to see the documents once.

If you are not willing to provide your ID then we shall not be able to proceed with business, either as a buyer or seller. We will be applying a strict rule of No ID = No Bid.

Corporate customers

Businesses will need to provide the following information and documents supporting:

  •  Full name
  • Registered number
  • Registered office address in the country of incorporation
  • Principal business address (if different from the registered office)

 And for private or unlisted companies

  •  Names of individuals who own over 25% of its shares or voting rights
  • Names of any individual(s) who otherwise exercise control over management or the company

 Verification will be accepted from appropriate sources such as

  •  Confirmation of the company’s listing on a regulated market
  • A search of the relevant company registry
  • A copy of the company’s Certificate of Incorporation


Executors and personal representatives

In the case of an estate of a deceased person in the course of administration, we ask to see:

  • court documents granting probate or letters of administration as evidence of authority
  • Lawyers and accountants acting in the course of their business as regulated firms who are not named executors/administrators will be asked for their practising certificates or an appropriate professional register

We will also need full details of the deceased as asked by our Valuations administration team.



If you are a Trust appointing our services we will need:

  • Name of the Settlor
  • Full name of the Trust
  • Nature, purpose and objects of the trust (e.g. bare, discretionary, testamentary, etc.)
  • Country of establishment
  • Name of all Trustees
  • Names of any beneficiaries
  • Name of any protector or controller

Not all items fall under these Anti Money Laundering regulations, however, as a regulated Art Market Participant we are obliged to perform CDD on all clients regardless of the value of transactions involved.

The AML regulations apply to works of art with a value equivalent to 10,000 euros or more. If you are buying or selling Works of Art over and above this threshold, Enhanced Due Diligence checks will be necessary. A definition of a Work of Art here is derived from s21(6) of the VAT Act 1994. As a brief summary this includes but not solely:

  • any mounted or unmounted painting, drawing, collage, decorative plaque or similar picture that was executed by hand; 
  • any original engraving, lithograph or other print which—
    • was produced from one or more plates executed by hand by an individual who executed them without using any mechanical or photomechanical process; and
    • either is the only one produced from the plate or plates or is comprised in a limited edition;
  • any original sculpture or statuary, in any material;
  • any sculpture cast which—
    • was produced by or under the supervision of the individual who made the mould or became entitled to it by succession on the death of that individual; and
    • either is the only cast produced from the mould or is comprised in a limited edition;
  • any ceramic executed by an individual and signed by him;
  • any mounted or unmounted photograph which—
    • was printed by or under the supervision of the photographer;
    • is signed by him; and
    • either is the only print made from the exposure in question or is comprised in a limited edition


If you would like to discuss any of the content outlined here further please contact our offices - CONTACT US