Over the past year, HMRC has intensified its enforcement of anti-money laundering (AML) regulations across the UK art market.
The Art Newspaper and Antiques Trade Gazette, both major publications for the sector, have reported on these developments, outlining the scale of penalties and the underlying compliance failures.
Our CEO and co-founder, Susan J. Mumford, shared her expertise in these articles, explaining why many Art Market Participants (AMPs) struggle to comply, what they can do to lower risk and the need for greater awareness.
A look at the numbers
The Art Newspaper noted that 50 fines were issued to AMPs between January and September 2024, with an average fine costing £3,000. The most common breach? Late registration.
According to the latest ATG article, the number and cost of fines rose from October to March 2025. During this period, 80 fines were issued, with the average fine now at £6,940. Breaches included inadequate risk assessments, poor customer due diligence, gaps in staff training and record-keeping issues, not just for trading while unregistered anymore.
“So far, most of the fines have been for failure to register. But that may only be the beginning,” warns Mumford. With 130 fines issued since 2024 for AML non-compliance, the crux of the matter is that penalties are real and increasing, and every AMP needs to be paying attention.
AML compliance starts with awareness
Whether you’re an established gallery, a part-time dealer, or an art advisor operating as a sole trader, you will caught by HMRC’s AMP regulations if art transactions in which you’re involved have a total value of €10,000. Your first line of defence is to be aware of this. Awareness makes compliance actionable at every level of your organisation, allowing you to recognise risks and respond accordingly.
Then, if you do discover a gap, such as missing registration or incomplete documentation, disclose this early to HMRC. While voluntary disclosure doesn’t necessarily guarantee leniency or that no fine will be issued, honesty is, and always will be, the best policy.
Working with, not against, HMRC can significantly reduce penalties and shows good intent. Remember, their goal is not to shut you down as a business, but rather to help you operate legally and protect the wider art market from abuse.
Conclusion
Don’t wait for a penalty before you take compliance seriously. Ask for help and lean into trusted partners like ArtAML™for guidance, training, and tech solutions to meet obligations.
Finally, if you would like to read the articles referenced in this blog, see the links below:
Latest round of money laundering penalties hit UK trade
Eighty art market firms hit with fines totalling over £500,000