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Artbidy.com

AML Policy

This Policy sets out the rules applied by Artbidy to prevent money laundering and terrorist financing and to fulfil its obligations relating to restrictive measures and financial sanctions.

This Policy constitutes public information for Artbidy Customers and business partners. It does not replace Artbidy’s internal AML/CFT procedure and does not disclose the detailed control methods or operational criteria applied by Artbidy.

§1 Artbidy and contact details


  1. The Artbidy.com website and Artbidy Auction House are operated by Łukasz Kuca, conducting business under the name Łukasz Kuca BDB Investments, ul. Nowomiejska 9, 96-100 Skierniewice, Poland, Tax Identification Number (NIP): 8361821946, hereinafter referred to as “Artbidy”.
  2. Artbidy Auction House also conducts its business at: ul. Świętojerska 5/7, building C, level -1, 00-236 Warsaw, Poland.
  3. For matters relating to this Policy and AML verification, please contact Artbidy:

a) by email: contact@artbidy.com,

b) by telephone: +48 604 238 369.

§2 Legal basis and purpose of the Policy


  1. Artbidy applies in particular:

a) the Polish Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, as amended, hereinafter referred to as the “AML Act”,

b) applicable national and European Union provisions concerning restrictive measures and financial sanctions,

c) Regulation (EU) 2016/679 of the European Parliament and of the Council, hereinafter referred to as the “GDPR”, and applicable Polish data protection legislation.

  1. In relation to transactions with a value equal to or exceeding the equivalent of EUR 10,000, whether carried out as a single operation or as several operations that appear to be linked, Artbidy is an obliged entity where it trades or acts as an intermediary in the trade of works of art, collectors’ items or antiques within the meaning of Article 120(1)(1)–(3) of the Polish Act on Value Added Tax.
  2. To the extent that Artbidy performs activities constituting real estate agency services, it also applies the obligations applicable to real estate agents.
  3. The measures applied by Artbidy are intended in particular to:

a) identify and verify the identity of Customers, persons acting on their behalf and Beneficial Owners,

b) establish the purpose and intended nature of a business relationship or transaction,

c) identify and assess the risk of money laundering and terrorist financing,

d) monitor transactions and clarify unusual transactions,

e) prevent Artbidy, its auctions, gallery sales, consignment sales, private sales or other services from being used for unlawful purposes,

f) fulfil Artbidy’s obligations towards the General Inspector of Financial Information and other competent authorities.

§3 Definitions


  1. Customer – a natural person, legal person or organisational unit without legal personality for whom Artbidy provides a service or performs an activity falling within the scope of Artbidy’s business.
  2. A Customer may include in particular:

a) a buyer,

b) a bidder,

c) a seller,

d) a consignor,

e) a person commissioning a private sale or purchase,

f) a person using intermediary services,

g) a person on whose behalf or for whose benefit a transaction is actually carried out.

  1. Beneficial Owner – any natural person who directly or indirectly exercises control over a Customer or the natural person on whose behalf a business relationship is established or a transaction is conducted, in accordance with the definition contained in the AML Act.
  2. PEP – a politically exposed person and, to the extent specified in the AML Act, their family member or a person known to be their close associate.
  3. AML Object – a work of art, collector’s item or antique within the meaning of Article 120(1)(1)–(3) of the Polish Act on Value Added Tax.
  4. Whether an object qualifies as an AML Object is determined by its actual characteristics and the applicable provisions of law, and not solely by the name of the category in which it has been listed on the Website.
  5. Linked Transactions – operations which, due to their parties, subject matter, timing, payment method, source of funds, common economic purpose or other circumstances, may constitute parts of a single transaction.
  6. Dividing a price, payment, instruction, collection or order into separate parts does not exclude their joint assessment as Linked Transactions.

§4 Application of customer due diligence measures


  1. Artbidy applies customer due diligence measures in the circumstances required by the AML Act, in particular:

a) in relation to a transaction covered by the AML Act concerning an AML Object with a value equal to or exceeding the equivalent of EUR 10,000, regardless of whether the transaction is carried out as a single operation or through several Linked Transactions,

b) when establishing or continuing a business relationship covered by the AML Act,

c) in relation to real estate agency services – in the circumstances specified in the AML Act,

d) where there is a suspicion of money laundering or terrorist financing,

e) where there are doubts concerning the truthfulness, validity or completeness of previously obtained identification data.

  1. Amounts expressed in euro are converted according to the average exchange rate announced by the National Bank of Poland and applicable on the date of the transaction or on the date on which the transaction is instructed, in accordance with the AML Act.
  2. For the purpose of determining whether a statutory threshold has been reached, Artbidy takes into account the full economic value of the transaction and any Linked Transactions.
  3. Dividing a payment into instalments or using several payment methods, bank accounts, persons or instructions does not automatically result in the operations being treated as separate transactions.
  4. Artbidy may also carry out verification below the statutory thresholds where this is justified by:

a) a risk assessment,

b) the need to apply sanctions,

c) fraud prevention,

d) the need to determine the provenance or legal status of an object,

e) transaction security,

f) the need to determine whether individual operations are linked.

  1. Verification may cover both the seller and the buyer, as well as persons acting on their behalf, entities financing the transaction and persons on whose behalf or for whose benefit the transaction is actually carried out.

§5 Customer due diligence measures


  1. To an extent appropriate to the identified risk, Artbidy may:

a) identify the Customer and verify their identity,

b) identify a person acting on behalf of the Customer and verify their identity and authority to act,

c) identify the Beneficial Owner, verify their identity and determine the Customer’s ownership and control structure,

d) obtain information concerning the purpose and intended nature of the business relationship or transaction,

e) establish the source of the funds intended for the transaction,

f) where required by law or justified by risk, establish the source of wealth of the Customer or Beneficial Owner,

g) verify PEP status,

h) verify whether the Customer, their representatives or Beneficial Owners appear on applicable sanctions lists,

i) examine whether a transaction is consistent with Artbidy’s knowledge of the Customer, their business and risk profile,

j) establish the provenance of an object, the seller’s legal title, ownership history, method of acquisition, authenticity and any restrictions on its trade or export,

k) monitor the business relationship and keep the information and documents held up to date.

  1. Verification may be conducted on the basis of:

a) identity documents,

b) registration documents,

c) powers of attorney,

d) the Polish Central Register of Beneficial Owners,

e) other public registers,

f) electronic identification means,

g) information obtained from payment service providers,

h) sanctions lists,

i) other reliable and independent sources.

  1. For the purpose of applying customer due diligence measures, Artbidy may process information contained in identity documents and, where necessary and proportionate, make copies of such documents.
  2. Artbidy does not automatically require a copy of an identity document in relation to every transaction.
  3. Verification is generally carried out before establishing a business relationship or conducting a transaction.
  4. Artbidy may make the following conditional upon completion of the required verification:

a) creating or maintaining a Customer account,

b) admitting a Customer to an auction,

c) accepting an absentee, online or telephone bidding instruction,

d) accepting an object for sale,

e) concluding or performing a consignment agreement,

f) concluding or performing a sales agreement,

g) accepting payment,

h) releasing or shipping an object,

i) paying funds to a seller or consignor.

§6 Required information and documents


  1. Artbidy may require a Customer who is a natural person to provide in particular:

a) their full name,

b) citizenship,

c) their Polish Personal Identification Number (PESEL) or, where no PESEL number has been assigned, their date and country of birth,

d) the series and number of their identity document and information concerning its validity,

e) residential address,

f) contact details,

g) tax residence information, where required,

h) in the case of a natural person conducting business activity – the registered business name, Tax Identification Number (NIP) and address of the principal place of business.

  1. Artbidy may require a Customer who is a legal person or another organisational unit to provide in particular:

a) its name or registered business name,

b) legal form,

c) registered office or business address,

d) Tax Identification Number (NIP),

e) where no NIP has been assigned – the country of registration, name of the relevant register, registration number and registration date,

f) current registration documents,

g) documents setting out its rules of representation,

h) details of the person representing the Customer,

i) a document confirming the representative’s authority to act,

j) information and documents concerning the ownership and control structure,

k) information concerning Beneficial Owners,

l) confirmation of registration or an extract from the relevant beneficial ownership register.

  1. Irrespective of the Customer’s legal form, Artbidy may require:

a) a declaration concerning the Beneficial Owner,

b) a declaration concerning PEP status,

c) information on whether the Customer acts in their own name and on their own account,

d) information concerning the person financing the transaction,

e) information concerning the person who is to receive the object or the proceeds from its sale,

f) information concerning any person who otherwise benefits from the transaction,

g) documents concerning the source of funds,

h) documents concerning the source of wealth,

i) documents concerning the provenance of and legal title to the object.

  1. A PEP declaration may contain the declaration of awareness of criminal liability for making a false statement, where required by the AML Act.
  2. Documents confirming the source of funds or source of wealth may include in particular:

a) bank confirmation or account documentation,

b) a sales agreement,

c) an inheritance document,

d) a donation agreement,

e) a loan or credit agreement,

f) a document confirming the payment of a dividend,

g) a document confirming income,

h) another document confirming the lawful source of the funds or wealth.

  1. Documents concerning the provenance of and legal title to an object may include in particular:

a) an invoice,

b) a sales agreement,

c) proof of purchase,

d) an inheritance document,

e) a donation agreement,

f) a certificate of authenticity,

g) provenance confirmation,

h) ownership history documentation,

i) import or export documentation,

j) another document confirming the right to dispose of the object.

  1. The scope of the required information and documents depends on the circumstances and risk assessment.
  2. Artbidy may request additional documents or an update of previously provided information.
  3. A Customer may agree with Artbidy that information unrelated to the purpose of verification be redacted from a document, provided that this does not prevent Artbidy from fulfilling its legal obligations.
  4. Payment by a third party, payment of funds to a third-party account or acting through an intermediary or representative must be disclosed in advance and may be subject to separate verification.
  5. Artbidy may refuse to accept a payment from a third party or to transfer funds to a third-party account.

§7 Risk assessment and enhanced due diligence


  1. Artbidy assesses risk taking into account in particular:

a) the type of Customer,

b) the Customer’s ownership and control structure,

c) the countries and geographical areas connected with the transaction,

d) the type of object,

e) the type of service,

f) the value of the transaction,

g) the manner in which the transaction is carried out,

h) the communication channel used to contact the Customer,

i) the payment method,

j) the source of funds,

k) the source of wealth,

l) the provenance of the object,

m) the purpose and frequency of transactions.

  1. A higher risk may be associated in particular with:

a) an opaque or excessively complex ownership structure,

b) acting through an undisclosed intermediary,

c) payment by a third party,

d) payment of funds to a third-party account,

e) cash payments,

f) an unusual settlement method,

g) a connection with a high-risk country,

h) a connection with a sanctioned country, person or entity,

i) PEP status,

j) the absence of a reliable ownership history for an object,

k) a high-value private sale,

l) the absence of an apparent legal or economic justification for the transaction,

m) an attempt to artificially divide a transaction or payment.

  1. Where a higher risk is identified, Artbidy applies enhanced due diligence measures, which may include in particular:

a) obtaining additional information about the Customer or Beneficial Owner,

b) obtaining additional information concerning the transaction or object,

c) obtaining additional documents concerning the source of funds or source of wealth,

d) carrying out additional verification using independent sources,

e) obtaining the approval of the person responsible for AML before establishing or continuing a business relationship,

f) requiring the first or entire payment to be made from a bank account held in the name or registered business name of the verified Customer,

g) enhanced monitoring of the transaction or business relationship,

h) in-person verification of the Customer,

i) the use of a secure electronic identification method.

  1. In relation to a PEP, Artbidy applies the measures required under the AML Act, including:

a) obtaining appropriate approval to establish or continue the business relationship,

b) establishing the source of wealth,

c) establishing the source of funds used in the transaction,

d) conducting enhanced monitoring of the business relationship.

  1. Measures relating to PEPs are also applied after the person has ceased to perform the relevant function for the period required by law and the applicable risk assessment.

§8 Payment and disbursement rules


  1. Artbidy prefers cashless payments and may require payment to be made by bank transfer or through a payment service provider designated by Artbidy.
  2. Artbidy may restrict or refuse a cash payment where this is justified by:

a) applicable law,

b) a risk assessment,

c) the value of the transaction,

d) transaction security,

e) an inability to establish the source of funds.

  1. Payment should be made by the verified buyer.
  2. Proceeds from the sale of an object should be paid to a verified bank account held by the seller or consignor.
  3. Any departure from the rules specified in paragraphs 3 and 4 requires Artbidy’s prior approval and verification of the persons participating in the settlement.
  4. Refunds are generally made using the same method and to the same source from which the original payment was received, unless the law or documented circumstances justify another solution.
  5. Artbidy may suspend:

a) release of an object,

b) shipment of an object,

c) transfer of ownership or possession of an object,

d) payment of proceeds to a seller or consignor

until the required verification has been completed and the settlement has been confirmed.

  1. Artificially dividing a transaction or payment in order to avoid verification, limits or legal obligations is prohibited.

§9 Inability to complete verification


  1. Where Artbidy is unable to apply the required customer due diligence measures, in particular due to:

a) a refusal to provide information,

b) the absence of required documents,

c) the provision of illegible or unreliable documents,

d) unresolved discrepancies,

e) reasonable doubts concerning the truthfulness of the information provided,

f) an inability to identify the Beneficial Owner,

g) an inability to establish the source of funds or source of wealth where required,

Artbidy takes the actions required or permitted by law.

  1. In the circumstances specified in paragraph 1, Artbidy may or must:

a) refuse to establish a business relationship,

b) refuse to carry out an occasional transaction,

c) refuse to register a Customer for an auction,

d) refuse to accept an instruction or bid,

e) refuse to process a purchase,

f) refuse to accept a payment,

g) refuse to release an object,

h) withhold payment until the matter has been clarified,

i) terminate an existing business relationship,

j) determine whether a notification must be submitted to the General Inspector of Financial Information or another competent authority.

  1. To the extent permitted by law, Artbidy may also refuse to carry out a transaction due to:

a) an unacceptable level of risk,

b) applicable sanctions,

c) suspected fraud,

d) the absence of a reliable legal title to the object,

e) suspected criminal origin of the object,

f) a risk of violating provisions concerning trade in cultural property,

g) a risk of violating provisions concerning the export of the object.

  1. Due to statutory confidentiality obligations, Artbidy may not be permitted to provide the Customer with full information concerning the reason for a delay, refusal, suspension or termination of the relationship.

§10 Suspicious transactions, GIIF and sanctions


  1. Artbidy conducts ongoing analysis of transactions covered by the AML Act.
  2. Artbidy takes steps to clarify transactions that are:

a) complex,

b) unusually high in value without justification arising from the circumstances,

c) conducted in an unusual manner,

d) lacking an apparent legal or economic justification,

e) inconsistent with Artbidy’s knowledge of the Customer,

f) raising doubts concerning the source of funds or the provenance of the object.

  1. In the circumstances specified by law, Artbidy:

a) provides the General Inspector of Financial Information with the required information or notifications,

b) makes documents and information available to competent authorities,

c) complies with requests and decisions issued by competent authorities,

d) suspends the execution of a transaction,

e) refrains from making funds or other assets available.

  1. To the extent required by law and appropriate to the identified risk, Artbidy checks Customers, representatives and Beneficial Owners against applicable Polish and European Union sanctions lists.
  2. Where a confirmed or reasonably suspected match with a sanctioned person or entity is identified, Artbidy may or must:

a) refuse to conduct the transaction,

b) suspend the execution of the transaction,

c) freeze or refrain from making funds or economic resources available,

d) provide information to the competent authority,

e) take any other actions required by law.

  1. Artbidy, its employees and its business partners may not disclose to the Customer or any third party:

a) the fact that particular information or a notification has been submitted to the General Inspector of Financial Information,

b) details of conducted analyses,

c) information concerning actions taken by competent authorities,

d) information whose disclosure is prohibited by law.

§11 Personal data processed for AML purposes


  1. The controller of personal data processed in connection with AML obligations is Łukasz Kuca, conducting business under the name Łukasz Kuca BDB Investments, ul. Nowomiejska 9, 96-100 Skierniewice, Poland, Tax Identification Number (NIP): 8361821946.
  2. The Controller may be contacted:

a) by email: contact@artbidy.com,

b) by telephone: +48 604 238 369.

  1. Artbidy may process in particular:

a) identification data of the Customer, representative and Beneficial Owner,

b) contact details,

c) information contained in identity documents,

d) information contained in registration documents,

e) information concerning ownership and control structures,

f) information concerning Beneficial Owners,

g) information concerning PEP status,

h) sanctions screening results,

i) transaction and payment information,

j) bank account information,

k) information concerning the source of funds or source of wealth,

l) information concerning an object, its provenance, ownership history and legal title,

m) risk assessment, analysis and verification results.

  1. The information may be obtained:

a) directly from the Customer or their representative,

b) from public registers,

c) from transaction documents,

d) from payment service providers,

e) from reliable verification databases,

f) from sanctions lists,

g) from publicly available sources,

h) to the extent permitted by law, from other participants in the transaction.

  1. The primary legal basis for processing is compliance with a legal obligation to which Artbidy is subject, pursuant to Article 6(1)(c) of the GDPR in conjunction with the AML Act and applicable sanctions legislation.
  2. Where applicable, the legal basis for processing may also be:

a) performance of a contract or taking steps prior to entering into a contract, pursuant to Article 6(1)(b) of the GDPR,

b) Artbidy’s legitimate interests, pursuant to Article 6(1)(f) of the GDPR, consisting of fraud prevention, protection of rights and transaction security.

  1. Providing information required under the AML Act is a statutory requirement. Failure to provide the required information or documents may prevent the establishment of a business relationship or the conclusion or performance of a transaction.
  2. Processing of personal data for AML purposes is not based on the Customer’s consent. Withdrawal of marketing consent does not affect the lawfulness of personal data processing for AML purposes.
  3. Personal data collected solely for the purpose of fulfilling AML obligations is not used for marketing purposes.
  4. Recipients of personal data may include, to the extent required by law or necessary for the handling of the relevant process:

a) the General Inspector of Financial Information,

b) the Polish National Revenue Administration,

c) law enforcement authorities,

d) public prosecutors,

e) courts,

f) supervisory and sanctions authorities,

g) payment service providers,

h) providers of identification and AML verification tools,

i) IT and data storage service providers,

j) legal and tax advisers and auditors bound by confidentiality obligations.

  1. Documents and information obtained through the application of customer due diligence measures, as well as transaction records and supporting evidence, are retained for five years from the date on which the business relationship ends or the occasional transaction is carried out.
  2. The results of required analyses are retained for five years from the date on which the analysis was conducted.
  3. In the circumstances specified by law, the General Inspector of Financial Information may require documentation to be retained for an additional period not exceeding five years.
  4. Other documents may be retained for a longer period where required under separate provisions of law or where necessary to establish, pursue or defend legal claims.
  5. Subject to the limitations provided by law, the data subject has the right to:

a) access their personal data,

b) rectify their personal data,

c) restrict the processing of their personal data,

d) lodge a complaint with the President of the Polish Personal Data Protection Office.

  1. The right to erasure, objection or data portability may not apply to the extent that processing is necessary to comply with a legal obligation or to fulfil tasks relating to the prevention of money laundering and terrorist financing.
  2. Detailed information concerning the protection of personal data is provided in the Artbidy Privacy Policy. The provisions of this section supplement the Privacy Policy in relation to personal data processed for AML purposes.

§12 Customer obligations


  1. The Customer is required to:

a) provide information and documents that are true, complete, current and not misleading,

b) promptly inform Artbidy of any change to previously provided information,

c) inform Artbidy of changes in representation, ownership structure or Beneficial Owners,

d) inform Artbidy of any change in PEP status,

e) cooperate in clarifying discrepancies and the circumstances of a transaction,

f) disclose whether they act in the name, on behalf or for the benefit of another person,

g) disclose whether the transaction is financed by another person,

h) refrain from using third-party accounts, funds or documents without informing Artbidy in advance,

i) refrain from taking any steps intended to circumvent verification, sanctions, limits or legal obligations.

  1. The Customer is required to provide additional explanations or documents where they are necessary for Artbidy to comply with its obligations.
  2. Providing false documents or statements may result in:

a) refusal to establish a business relationship,

b) refusal to carry out a transaction,

c) termination of the business relationship,

d) actions required under applicable law.

§13 Customer confidentiality


  1. Artbidy protects information concerning its Customers and does not publicly disclose the identity of a buyer or seller without an appropriate legal basis, in particular without that person’s consent.
  2. The principle of confidentiality, including the confidentiality of private sales, does not restrict Artbidy’s right or obligation to provide information to:

a) the General Inspector of Financial Information,

b) courts,

c) law enforcement authorities,

d) public prosecutors,

e) tax authorities,

f) supervisory or sanctions authorities,

g) payment service providers,

h) verification service providers,

i) other authorised recipients,

where the disclosure is required by law or necessary to conduct the transaction.

  1. Information concerning Customers is disclosed only to the extent necessary to achieve the relevant purpose.

§14 Final provisions


  1. Artbidy applies customer due diligence measures in a manner proportionate to the identified risk.
  2. This Policy does not restrict Artbidy’s right to request additional information or documents where justified by:

a) applicable law,

b) a risk assessment,

c) transaction security,

d) the need to establish the source of funds or the provenance of an object.

  1. This Policy does not replace:

a) the Website Terms and Conditions,

b) the Auction Terms and Conditions,

c) the terms and conditions of a particular auction,

d) a consignment agreement,

e) a sales agreement,

f) an intermediary agreement,

g) individual terms of a transaction.

  1. In the event of any conflict between this Policy and mandatory provisions of law, the mandatory provisions of law shall prevail.
  2. Artbidy may update this Policy in particular in the event of:

a) changes in applicable law,

b) new guidance issued by competent authorities,

c) changes to Artbidy’s business model,

d) changes to available payment methods,

e) changes to the manner in which services are provided,

f) changes in the identified risk of money laundering or terrorist financing.

  1. The current version of this Policy is published on the Website together with its effective date.
  2. This Policy is effective from 2 November 2026.
  3. Questions concerning this Policy or the verification process should be sent to: contact@artbidy.com.
Koszyk