How it works for your auction house
Buyer and consignor each get their own case file. You see in your own system whether a purchase reaches € 10,000. A corporate buyer, such as a foundation, is completed from the Dutch trade register, and you record directors and UBOs in the structure. You see straight away who may be a UBO.
You enter each party and invite them with a procedure, with the steps in the order you want. Each party does their part in the client portal, and the portal and emails carry your house style. Your client logs in with a code by email and picks up where they left off. Whatever the consignor uploads goes straight into document management, and you record custom fields for the artwork.
You draw up purchase and consignment agreements in the contract builder, with a numbered table for the works. Each party signs exactly the version you sent. Templates for forms and contracts are ready to use.
You screen buyer and consignor for PEP status, sanctions and adverse media going back ten years, and a foundation also on its sector. Without a hit the risk is medium, and a reassessment follows after two years.
The handler submits each case file and a reviewer approves or rejects it. You keep the whole case file as a PDF.
What the Wwft asks of an art dealer
Anyone buying or selling works of art on a professional basis falls under the Wwft, the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act, once a payment reaches € 10,000 (Article 1a(4)(k)). Art intermediaries fall under part (j), and the dealer is also bound by the ban on cash of € 3,000 or more (Article 1f).
The Minister of Finance is formally the supervisor (Article 1d(1)(e)). Since 1 January 2026 the DFEI, successor to the Bureau Toezicht Wwft, does that work. The art trade guidance, with a risk matrix, dates from January 2026.
In RiskResolve you keep invoices and bills of sale in the case file. The dealer judges an artwork’s chain of provenance, and if a transaction looks unusual, the dealer files the report with FIU-the Netherlands.
Questions from galleries and auction houses
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