Anti-Money Laundering (AML) Policy

For Maudie Brady – selling my own original works. References to ‘I’ in this policy include, where applicable, my agent, accountant, or other authorised team members.

Purpose

This policy outlines my commitment to preventing money laundering and terrorist financing in accordance with Italian and EU regulations. As an artist selling my own original works, I adopt a risk-based approach to ensure compliance and protect my business.

Scope

This policy applies to all sales of my artwork, regardless of channel (online or offline). It covers one-off and cumulative transactions above €10,000 or those involving unusual payment methods. I am avoiding high-risk jurisdictions by following the EU Commission list of high-risk third countries and disallow sales to these regions.

Customer Due Diligence (CDD)

A. Identification

  • For transactions below €10,000, I collect standard customer information (name, email, shipping address).
  • For transactions €10,000 or above, I verify the customer’s identity using a government-issued ID (passport, national ID, or business registration).
  • If the purchased artwork is shipped to a different address (e.g. gifts), I will verify the buyer’s identity and, where possible, also obtain the recipient’s details to prevent misuse.

B. Risk Assessment.

I assess risk based on:

  • Transaction size (large or unusual amounts).
  • Cumulative transactions within a short timeframe that exceed €10,000.
  • Payment method. I only accept bank transfers, credit card payments in the customer’s name, or other approved payment service methods. Cash, cryptocurrency, or third-party payments (i.e. payments made from someone else’s account or card) are not allowed.
  • Customer behaviour (reluctance to provide ID, rushed transactions).
  • Geographic risk (customers from EU high-risk third countries).
  • Low-risk transactions require no further action. High-risk transactions trigger enhanced due diligence (e.g., requesting proof of funds origin).

Monitoring and Reporting

I monitor for structuring (splitting payments to avoid thresholds), unusual customer behaviour, or inconsistencies between buyer and payment details and transactions with unusual patterns (e.g., rapid successive purchases, payments from high-risk countries).

If a transaction appears suspicious, I:

  • Pause the sale and request further information.
  • Report to the UIF if money laundering is suspected, via the UIF online portal (without informing the customer).
  • Document the assessment (“ID verified, no red flags” or “Reported to UIF”).

Record-Keeping

I retain records of customer IDs, invoices, and transaction details for at least 10 years, or longer if required by Italian law.

Responsibilities

I, Maudie Brady, am responsible for AML compliance and reporting.
I review and update this policy annually (or immediately) if new legal obligations are introduced, or as regulations change.

Training and awareness

I ensure that all relevant parties (such as my agent and accountant) are aware of this policy and of potential red flags for money laundering.

Contact for Questions

For questions or concerns, use the contact page.