--- title: Your AML Checklist from FCS Compliance description: Free AML Checklist from FCS Compliance - suitable for HMRC-regulated Art Market Participants (AMPs). --- [Skip to content](https://services.fcscompliance.co.uk/aml-checklist-art-market#main-content) [![FCS\_Horiz\_RGB-2](https://services.fcscompliance.co.uk/hs-fs/hubfs/Logos/FCS%20Logos/FCS_Horiz_RGB-2.png?width=1500&height=290&name=FCS_Horiz_RGB-2.png)](https://fcscompliance.co.uk/) - Industries Show submenu for Industries - [Art Market](https://fcscompliance.co.uk/art/) - [Property Market](https://fcscompliance.co.uk/property/) - Services Show submenu for Services - [Primary Services](https://fcscompliance.co.uk/fcs-services/primary-services/) - [Anti Money Laundering Training](https://fcscompliance.co.uk/fcs-services/training/) - [Customer Due Diligence (CDD)](https://fcscompliance.co.uk/fcs-services/customer-due-diligence-cdd/) - [Consultancy Services](https://fcscompliance.co.uk/fcs-services/consultancy-services/) - [AML Protect](https://amlprotect.co.uk/) - [Updates](https://fcscompliance.co.uk/updates/) - [About Us](https://fcscompliance.co.uk/company-overview/) Open main navigation Close main navigation - Industries Show submenu for Industries - [Art Market](https://fcscompliance.co.uk/art/) - [Property Market](https://fcscompliance.co.uk/property/) - Services Show submenu for Services - [Primary Services](https://fcscompliance.co.uk/fcs-services/primary-services/) - [Anti Money Laundering Training](https://fcscompliance.co.uk/fcs-services/training/) - [Customer Due Diligence (CDD)](https://fcscompliance.co.uk/fcs-services/customer-due-diligence-cdd/) - [Consultancy Services](https://fcscompliance.co.uk/fcs-services/consultancy-services/) - [AML Protect](https://amlprotect.co.uk/) - [Updates](https://fcscompliance.co.uk/updates/) - [About Us](https://fcscompliance.co.uk/company-overview/) - [Contact](https://fcscompliance.co.uk/contact-us/) [Contact](https://fcscompliance.co.uk/contact-us/) ![aml\_checklist\_scroll\_header](https://services.fcscompliance.co.uk/hs-fs/hubfs/aml_checklist_scroll_header.gif?width=1545&height=560&name=aml_checklist_scroll_header.gif "aml_checklist_scroll_header") # 9 things you must do to help you be compliant Do you know what you need to do to remain compliant with the UK's Money Laundering Regulations (MLRs)?  To make things easy for you, we've created a list of the top 8 things that you must do to help you be compliant. [Read the list](https://services.fcscompliance.co.uk/aml-checklist-art-market#AML-checklist) [Contact us](https://services.fcscompliance.co.uk/aml-checklist-art-market#contact-us) ![AMP AML Checklist Landing Page](https://services.fcscompliance.co.uk/hs-fs/hubfs/AMP%20AML%20Checklist%20Landing%20Page.jpg?width=1536&height=920&name=AMP%20AML%20Checklist%20Landing%20Page.jpg "AMP AML Checklist Landing Page") ## FCS Compliance's AML Checklist --- ### 🗒️ 1) Annually conduct a business Risk Assessment Learn why you must carry out a Risk Assessment... You must carry out annual written AML Risk Assessment detailing the extent to which you and your business are exposed to Money Laundering, terrorist financing and proliferation financing. Even if your business has not changed, the risk profiles, Government Guidance and often the regulations are constantly evolving, which is reflected in our consistently updated Risk Assessment.   If you have not updated your risk assessment in the last year, it is automatically out of date. A risk assessment should be tailored to your company size, the makeup of client base and geographic exposure to ensure your business's risks are clearly documented, understood and managed to help avoid any pitfalls. HMRC will review this documentation as part of an inspection.  Need support with your Risk Assessment? [FCS can help](https://fhiu5.share-eu1.hsforms.com/23iMjVUQ1S7WnEyKvYppcMg).  ### 🗒️ 2) Create and annually update written Policies & Procedures You must create and maintain a Policies & Procedures because... 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.](https://fhiu5.share-eu1.hsforms.com/23iMjVUQ1S7WnEyKvYppcMg)   ### 🗒️ 3) Conduct Customer Due Diligence (CDD) If you don't do CDD you may be at risk of... 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](https://fcscompliance.co.uk/fcs-services/customer-due-diligence-cdd/). ### 🗒️ 4) Check High Risk Jurisdictions during CDD New guidance says you must consider... 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](https://www.fatf-gafi.org/en/home.html)(FATF)** Black (NOT THE Grey List) countries require **Enhanced[Due Diligence](https://fcscompliance.co.uk/fcs-services/customer-due-diligence-cdd/)(EDD)**.   *As of July 2026, the list of jurisdictions to which you* ***must consider*** *applying EDD is much longer and includes:* - *The current list of 22 FATF* ***Grey List*** *countries* - *Countries* ***neighbouring the Black List Countries****, such as China, India or Türkiye?* - Countries with inadequate AML and CTF measures, **such as the US and China** - Citizenship by Investment (CBI) countries such as Malta, Montenegro, Saint Vincent and the Grenadines, St. Kitts and Nevis, St. Lucia, Turkey, **UAE,** Vanuatu - Countries with laws aiding financial secrecy, such as **Switzerland,** UAE, BVI, Bahamas, Bermuda, Jersey, Guernsey, Isle of Man, **Luxembourg, Liechtenstein, Monaco, Singapore, Hong Kong, US States of Delaware, Nevada and Wyoming** - Countries on National Risk Assessment 2025, such as Russia, China, **Hong Kong, Turkey, UAE** - Countries vulnerable to - Bribery and corruption - Tax evasion - Capital flight - Conflict zones - Organised crime activity And many more... Have more questions about which countries are High Risk and require EDD? [Find out more about how our AML hotline can help](https://services.fcscompliance.co.uk/aml-hotline?hsLang=en-gb).    Or [take one of our refresher courses](https://fcscompliance.co.uk/fcs-services/training/) to make sure your knowledge is up to date. ### 🗒️ 5) Report suspicious activity and fellow AMPs The consequences of not reporting are... 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](https://www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/money-laundering-and-illicit-finance/suspicious-activity-reports).     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](https://www.gov.uk/guidance/suspected-breach-of-financial-sanctions-what-to-do).   If you fail to file under these circumstances, you risk committing a criminal offence. HMRC is crystal clear: 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 report them to HMRC. Check if fellow AMPs are registered on [AML Protect](https://amlprotect.co.uk/). Need help knowing when to file a SAR? Or how to file one? [FCS is here to help.](https://fhiu5.share-eu1.hsforms.com/2SSgXuNFkS5yo1pNPSeg5zg)   ### 🗒️ 6) Train relevant staff on AML at least once a year Why training is so important... It is a legal requirement that relevant staff must be trained on their AML obligations at minimum once a year and more often as appropriate. Until July 2026, when HMRC issued new Guidance, it was not clear that this was a minimum annual requirement.  New employees must also be trained as should those whose roles or responsibilities change and those who indicate weak AML knowledge. It is also important to keep track of which employees are trained when, and what they learned. Staff not trained or just need updating? [View FCS Compliance's range of AML training](https://fcscompliance.co.uk/fcs-services/training/).  ### 🗒️ 7) You must train all staff on Suspicious Activity Reports You must know how to complete a SAR because... Under the July 2026 HMRC Guidance, all staff must be trained on matters relating to Suspicious Activity Reports, because of the risk in this area of personal liability.  If you are involved in a transaction with another UK Art Market Participant who is not registered but should be, then HMRC advises you not to conclude the transaction and to inform HMRC and the NCA. Need help knowing when to file a SAR? Or how to file one? [FCS is here to help.](https://fhiu5.share-eu1.hsforms.com/2SSgXuNFkS5yo1pNPSeg5zg)   ### 🗒️ 8) AMP Registration: Register, renew and keep it current Learn when you're eligible and how to register... 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 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. Your AMP Registration with HMRC must be current and accurate. You must notify HMRC within 14 days of appointing a different Nominated Officer and/or Compliance Officer, or of any other change affecting an AMP's Registration. Also check that all beneficial owners, officers and managers (BOOMs) requiring approval are correctly recorded with HMRC.   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.](https://www.gov.uk/anti-money-laundering-registration)   Already registered? Set up for free renewal reminders on[AML Protect](https://amlprotect.co.uk/)  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.  ### 🗒️ 9) Appoint a Nominated Officer This nominated officer is known as... 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.](https://fcscompliance.co.uk/fcs-services/training/)   ## Find out about how FCS can help FCS Compliance has a range of services that can help you with any of the items mentioned in this list. Need help? Get in touch with our expert team to discuss how we can help. [Enquire](https://services.fcscompliance.co.uk/aml-checklist-art-market#contact-us) ## How FCS can help FCS Compliance helps Art Market Participants (AMPs) across the sector meet their legal AML obligations as set out by the UK government. Headed by Rena Neville, a leading art market specialist and legal expert, FCS Compliance Art Division is chosen for the extensive expertise, experience and market knowledge offered by the [team](https://fcscompliance.co.uk/company-overview/) and for its comprehensive range of practical, cost-effective [services](https://fcscompliance.co.uk/fcs-services/) designed to satisfy every legal AML requirement. ### Policies & Procedures and Risk Assessments Our expert team can carry out a risk assessment and deliver a comprehensive manual so that your business is in order and you're ready for any unexpected HMRC submission request. [Enquire about our support](https://fhiu5.share-eu1.hsforms.com/23iMjVUQ1S7WnEyKvYppcMg) ### HMRC Penalty & Fine Replies If you are notified that you are subject to a penalty from HMRC, we will help you evaluate the merits of HMRC’s position and whether the amount may be reduced, wholly eliminated or even refunded [Get help with a penalty](https://services.fcscompliance.co.uk/aml-checklist-art-market#contact-us) ### Customer Due Diligence We set ourselves apart by going far beyond the AML/Know Your Customer (KYC) checks typically provided by online verification systems. Our experts deploy rigorous practices essential for compliance. [Enquire about CDD support](https://fcscompliance.co.uk/fcs-services/customer-due-diligence-cdd/) ### AML Training Our range of CPD certified courses is expert-led, interactive, and designed by seasoned AML experts with decades of industry experience. Our sessions are delivered live for a truly engaging and dynamic learning experience [View training dates](https://fcscompliance.co.uk/fcs-services/training/) ### File Reviews On-demand or scheduled audits of your CDD files, with clear, written feedback on the quality and completeness of your due diligence. We'll highlight red flags, spot gaps and help you address them, giving you greater confidence and control.  [Enquire about file reviews](https://fcscompliance.co.uk/fcs-services/consultancy-services/) ### AML Protect Every year, HMRC fines property professionals just for late registrations. AML Protect is a free service that reminds you, in advance, to renew your HMRC registration. It takes two minutes to register and could save you thousands. 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