Money laundering supervision for art market participants
Find out if you’re an art market participant and need to register with HMRC under the money laundering regulations.
Who should register
You have to register with HMRC if your business operates as an art market participant under the money laundering regulations.
An art market participant under the money laundering regulations is a company or sole practitioner who is either:
- ‘by way of business’ trading in, or acts as an intermediary in, the buying or selling of works of art where the transaction value (or a series of linked transactions) is 10,000 euros or more
- the operator of a Freeport storing works of art in the Freeport and the value for a person (or a series of linked persons) is 10,000 euros or more
If you have questions about ‘by way of business’, contact HMRC.
A Freeport is a warehouse or storage facility within an area chosen by HM Treasury as a special area for customs purposes. This is in line with section 100A(1) of the Customs and Excise Management Act 1979.
‘Work of art’ has the same meaning as in part 5(a) and 6 in section 21 of the Value Added Tax Act 1994.
Intermediaries
An intermediary is someone who, by way of business, is actively involved in the sale or purchase of a work of art, on behalf of a seller or buyer. This involves dealing with more than one party. The intermediary will have authority to act on behalf of a seller or buyer.
You should register as an art market participant if you:
- negotiate the price of the art piece with another art market participant
- act on behalf of a customer during a sale or purchase
You do not need to register as an art market participant if you only:
- provide art advice to your customer
- charge a fee to carry out research or provenance checks on a work of art but are not involved in the sale or purchase
- introduce your customers to an art market participant who then carries out the transaction
- provide non-regulated services, such as framing, shipping or art installation
Artists
You do not need to register as an art market participant if you are an artist who:
- sells their own work directly to customers as an individual or through a business you own
- does not sell art created by other people
When to register
You must register with HMRC if you meet the criteria. You’ll be able to pay your registration fees at the same time.
Annual supervision
At the end of each registration period we’ll send you a notice inviting you to update your registration with HMRC and pay the annual fee on all your listed premises. If you do not need your registration to continue then you should sign in to your online account and update your registration.
If you do not pay the correct fee then we may cancel your registration and remove your business from the anti-money laundering register.
Get more information
You can find more information about art market participants guidance for money laundering supervision, including:
- who should register
- how to agree to the conditions under the money laundering regulations
- other related legislation
It covers:
- what you must do to protect against the risks of money laundering and terrorist financing
- how to report suspicious activity
You can also watch recorded webinars to find out more about money laundering supervision.
You can email [email protected] if you are:
- registered with HMRC as a non-established taxable person (NETP) and are unable to register for supervision online
- not sure if your activities fall to be supervised by HMRC
Updates to this page
Published 7 February 2020Last updated 6 August 2024 + show all updates
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Information has been updated to confirm that in this guidance, 'work of art' has the same meaning as in part 5(a) and 6 in section 21 of the Value Added Tax Act 1994.
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Guidance for intermediaries and artists about whether they need to register as an art market participant has been added.
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Updated the 'annual supervision' section because 'annual renewal' has been renamed to 'annual supervision' and 'renewing your registration' has been renamed to 'updating your registration'.
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First published.