8 things you must do to help you be compliant

A party must register with HMRC as an art market participant if, you by way of business, one:

• Trades, or acts as an intermediary or
• In the sale or purchase of a work of art, as defined in the UK Regulations for
• A value or total purchase price of 10,000 euros or more
• In a single or a series of linked transactions.

One must register as an art market participant with HMRC if one is a freeport operator who stores works of art whose value amounts to €10,000 or more for a single person or persons who are linked.

Art market participants must annually renew their registration and/ or update it as appropriate during the year.

The vast majority of fines HMRC hands out are for not being registered, failing to renew annually the registration, or for failing to update registration information, as required.  

Have a question about whether or how to register, we can help. Or, if you know you should register, you may do so Register here.

Already registered? Set up for free renewal reminders on AML Protect 
To help AMPs remember when to renew their registrations, FCS developed ‘AML Protect’, a free reminder service that automatically alerts you when it is time to renew your registration, as failure to re-register could subject you to an HMRC fine. 

Based on your risk assessment, you must maintain a written prescribed range of policies, controls and procedures on how your business mitigates against the risks identified in the Risk Assessment. 

This needs to be tailored to your business and aligned with the legal and regulatory obligations of the business. HMRC will review this documentation as part of an inspection. 

How confident are you that your Policies, controls and procedures reflect current Government Guidance? FCS can help.  

CDD must be conducted before the title to a work of art passes and before the property is released, or before establishing a business relationship. Red Flags, in particular Human Ref Flags (such as a customer asking odd or unusual questions or being reluctant to answer your questions) may arise at any time, but often arise when conducting due diligence.   

How confident are you that you and your client-facing team are familiar with the various Human Red Flags that HMRC has identified?  Enquire about FCS Compliance's pay-as-you-go CDD services.

You must appoint a nominated officer who will deal with your AML compliance. They are known as a Money Laundering Reporting Officer (MLRO). If you are self-employed, then you are automatically the MLRO for your business. 

The MLRO bears the responsibility of ensuring a business is fully AML compliant and can be personally liable should serious violations occur. 

Does your MLRO know their duties? Get Specialist MLRO training with FCS.  

It is a legal requirement that relevant staff must be regularly trained on their AML obligations. Given the annual updates and changes to the UK regulatory landscape for art market participants, it is advisable to refresh training annually to protect yourself from financial and reputational risk.  New employees and existing employees whose roles change both present particular risks to businesses.  

Staff not trained or just need updating? View FCS Compliance's range of AML training. 

If at any point during your transaction, you have a reasonable basis even to suspect money laundering or terrorist financing activities have taken or are taking place, you must report that suspicious activity to the National Crime Agency (NCA) by completing a Suspicious Activity Report (SAR). – Find out more here.    

OFSI: If you have a reasonable basis for suspicion that a party is attempting to or breaching UK Sanctions, you have a mandatory duty to report to the Office of Financial Sanctions. Find out more here.  

If you fail to file under these circumstances, you risk committing a criminal offence.

HMRC: If you are involved in a transaction with another art market participant who is not registered but should be, then HMRC advises you not to conclude the transaction and to inform HMRC

Need help knowing when to file a SAR? Or how to file one? FCS is here to help.  

As of 2025, there are new, more subtle factors to consider in determining which are High Risk jurisdictions. As before, the Financial Action Task Force (FATF) Black and Grey List countries should be considered and if present, require Enhanced Due Diligence (EDD).

Additional jurisdictional risks may include*:

• Bribery and corruption
• Tax evasion
• Capital flight
• Conflict zones
• Organised crime activity
  
  

There are additional jurisdictions that include specific risks of Proliferation-finance — as well as with politically exposed persons (PEPs), governments, and government-owned entities from these four countries*:

• Iran
• North Korea
• Russia
• Syria

*This exclusion list was last updated October 2025.

AMPs must also consider the risks of conducting transactions in or with customers from countries adjacent to the High Risk countries.

Have more questions about which countries are High Risk and require EDD? Find out more about how our AML hotline can help. 

Or take one of our refresher courses to make sure your knowledge is up to date.