AML for the Art Market: What UK Accountants Need to Know

The art trade has a reputation for secrecy, high values and portable assets, which is exactly what money launderers and sanctions evaders look for. In the UK, businesses that deal in art are supervised by HMRC under the Money Laundering Regulations 2017. If your accountancy firm acts for galleries, dealers, auction houses, advisers or collectors, you need to know where those clients sit under the rules and which risks to watch. This guide sets out the registration rules, the 2026 threshold change, the sanctions duties that arrived in 2025, and what accountants should check at client acceptance. It sits alongside our guide to HMRC AML supervision and registration.

Who counts as an art market participant

HMRC's guidance says a business must register as an art market participant if, by way of business, it trades in works of art or acts as an intermediary in their sale or purchase, and the value of the transaction, or a series of linked transactions, reaches the threshold. Operators of a freeport that stores works of art are covered at the same value for a person or linked persons.

The guidance is specific about who is in and who is out:

• In: galleries, dealers and auction houses that buy or sell art, and intermediaries who negotiate a price with another art market participant or act on a customer's behalf in a sale or purchase.
• Out: people who only give art advice, who charge for research or provenance checks without taking part in the sale or purchase, who simply introduce a customer to a participant who carries out the deal, or who supply non-regulated services such as framing, shipping or installation.
• Artists: an artist selling their own work directly, or through a business they own, does not need to register, as long as they do not sell art made by other people.

"Work of art" takes its meaning from the VAT Act 1994, so check that definition rather than assuming it is limited to paintings.

The threshold is now £10,000

Until recently the threshold was expressed as 10,000 euros. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, which took effect on 30 June 2026, change regulation 14(c) so the figure for high value dealers, casinos, auction platforms and art market participants is £10,000. HMRC's registration page still quoted euros when we checked it for this article, so confirm the current figure with HMRC before you advise a client on whether they are in scope. Remember that linked transactions count together, and that a client who splits payments to stay under the line is a red flag in its own right.

Registration and supervision

A business that meets the criteria must register with HMRC and pay the registration fee at the same time. After that, HMRC sends a notice at the end of each registration period inviting the business to update its registration and pay the annual fee for all listed premises. HMRC may cancel the registration and remove the business from the register if the correct fee is not paid.

Enforcement has been real. Reporting by ARTnews in March 2025 said HMRC fined nearly 50 art businesses between January and September 2024 for failing to register by the June 2021 deadline, with penalties averaging over £3,000 and reaching £13,000 at the top end. If a client trades in art and you cannot find evidence of registration, treat that as a client-acceptance issue, not a paperwork detail.

Sanctions: art market participants became relevant firms in 2025

On 14 May 2025, art market participants and high value dealers became "relevant firms" for financial sanctions reporting purposes. OFSI's June 2025 threat assessment says Russian designated persons and their enablers pose the most significant threat, and that it is highly likely high value goods owned by designated persons in the UK have not been reported to OFSI. It points to portable goods, complex corporate holding structures, and opaque payments in cash or cryptoassets.

The assessment asks firms to report to OFSI as soon as practicable if they know or have reasonable cause to suspect that a person is a designated person or has breached UK sanctions. A suspicious activity report to the NCA is required where money laundering is suspected, and it does not replace the OFSI report. OFSI says failure to report is an offence, and that it can impose monetary penalties of up to £1 million or 50% of the estimated value of the funds or economic resources involved. Our guide to UK financial sanctions and OFSI reporting for accountants covers how the same duties apply to your own firm.

Red flags the OFSI assessment highlights

Several indicators in the assessment translate well to an accountant reviewing an art client's books or onboarding a new one:

• Counterparties with links to sanctioned jurisdictions, or who try to hide them, including through a "golden passport".
• Names that match the OFSI Consolidated List once spelling and transliteration variations are allowed for.
• Refusal to provide know-your-customer information, or rushed or delayed transactions.
• Prices well above or below market value, or an unclear source of funds or ownership history.
• Payments split to stay below the £10,000 threshold.
• Complex corporate structures, several intermediaries, or payments that mix cash and cryptoassets.
• A non-designated person claiming ownership of an asset bought with a designated person's money, or paying storage costs a designated person used to pay.

Our practical guide to money laundering red flags for accountants shows how to log and escalate concerns like these.

What accountants should do at client acceptance

If the client trades in art, confirm whether they are in scope at the current threshold and ask for proof of HMRC registration. Review their own business risk assessment and procedures, because a registered business is expected to have both. Understand who owns and controls the business and where its money comes from, particularly for dealers using holding companies or offshore storage. Check names against the OFSI list and record the result. Finally, decide whether the engagement fits your own risk appetite, and document it, as set out in our guide to AML and financial crime CPD for accountants.

Frequently asked questions

Does an art adviser need to register?

Not if they only give advice, carry out research or provenance checks without taking part in the deal, or introduce customers to a participant who completes it. An adviser who negotiates the price or acts for a customer in the purchase or sale is an intermediary and may need to register.

Do artists need to register?

Not when selling their own work directly or through a business they own, provided they do not sell art made by others.

Does the 2026 change make the threshold higher or lower?

The figure is now £10,000 rather than 10,000 euros. One law firm's commentary on the amendments (Bishop & Sewell, June 2026) put 10,000 euros at roughly £8,650, which would make the new threshold higher in practice. Check the current rule before relying on this.