The UK Money Laundering and Terrorist Financing Regulations 2019 took effect on 10th January 2020 which introduced ‘Art Market Participants’ (“AMPs”) as a new obliged entity.
Does your business need to comply?
The definition of AMPs according to the 2019 Regulations[1] is:
“a firm or sole practitioner who by way of business trades in, or acts as an intermediary in the sale or purchase of, works of art and the value of the transaction, or a series of linked transactions, amounts to 10,000 euros or more”.
UK Legislation vs Guidance:
The legislation itself was written by HM Treasury and the Guidance was commissioned by The British Art Market Federation (“BAMF”), with approval by HM Treasury. Originally published in early 2020, the Guidance was updated on 30th June 2022 and again on 6th February 2023.
Take a deep dive and read the Guidance:
Head to the gov.uk page here or open to the PDF by clicking the image below:
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[1] See http://www.legislation.gov.uk/uksi/2019/1511/contents/made
This article was updated on 20th September 2022 to reference and link to the updated British Art Market Federation Guidance, which replaces the original version published in 2020. It was updated again on 9th March 2023 with a link to the updated Guidance from 6th February 2023.