Art market participants
Since January 2020, art market participants dealing in works of art with a value of EUR 10,000 or more per transaction (or linked series) have been supervised by HMRC under the MLR 2017 as amended.
Where the regime bites
The regime covers dealers, galleries, auction houses and intermediaries. HMRC operates a dedicated Art Market Participant (AMP) supervision team and publishes sector-specific guidance developed with the British Art Market Federation (BAMF) and the Antiquities Dealers' Association.
The sector's principal risk is the use of high-value, portable, subjectively valued assets to move and store illicit wealth — often through intermediaries acting in an agency capacity for undisclosed principals.
What supervisors expect
Register with HMRC before conducting any transaction meeting the threshold, and maintain BOOM fit-and-proper approvals.
Identify and verify both buyer and seller, and where an agent is acting, verify the identity of the underlying principal and the basis of the agency.
Retain provenance documentation alongside SoF evidence, and apply EDD to transactions involving higher-risk jurisdictions or opaque ownership.
Enhanced diligence for works held in freeports or bonded warehouses, given the recognised layering risk associated with long-term high-value storage.
Recurring risk indicators
- Undisclosed principals and agency chains
- Subjective and volatile valuations
- Freeport and bonded storage arrangements
- High-value private sales without market comparables
- PEP buyers using corporate collectors
Advisory support for the sector
- HMRC AMP registration
- Provenance and CDD integration
- Sector-specific staff training
- Independent policy review