What is a ‘work of art’ for AML in the art market? (UK)
Establishing the definition of a 'work of art' is key to meeting obligations as an Art Market Participant: It is only transactions of a set value in works of art that trigger the requirement to...
UK Art Market Participants: Register with the NCA’s new SAR portal
After many months' testing, the National Crime Agency has launched a new Suspicious Activity Report portal.The NCA states in their announcement: "Once your organisation has registered, it is...
Supervised Business Register (UK): Is your/another business registered as an Art Market Participant to legally transact?
Find out if your business - or a colleague with whom you're doing business, has successfully registered for Money Laundering Supervision. Why is this important? For businesses with a UK operation:...
Monthly Currency Conversion: EUR to GBP
Updated 20th September 2023The transaction value that triggers the need to conduct Customer Due Diligence is €10,000 (unless there's potentially suspicious activity, in which case value is...
Historic conversion rates for 10,000 EUR to GBP (UK) since January 2020 – for Art Market Participants
As an art market participant, you are required to complete due diligence checks on any culmulative transactions (including VAT and additional fees) that meet or exceed the threshold of 10,000 EUR....
High-risk jurisdictions for Art Market Participants: Why does this matter and how do you get answers?
Risk guidance published by HMRC (June 2021) highlights the importance of identifying if funds have come from a high-risk jurisdiction. Why is this important? According to the risk guidance: Such...
What to expect if your art business has an AML intervention with HMRC
Interventions are now taking place of art businesses regulated for AML in the UK. This overview has been put together to help set your expectations of what might be covered. Keep reading to discover...
Understanding updates to BAMF’s AML Guidance for Art Market Participants (6th February 2023)
The British Art Market Federation (“BAMF”) Guidance was updated for UK Art Market Participants (“AMPs”) on 6th February 2023. HM Revenue & Customs (“HMRC”) as regulator sent an email update with...
BAMF Guidance for UK Art Market Participants – last updated 6th February 2023
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...
Art fair walk-arounds and interventions by HMRC: The regulation of Art Market Participants is getting serious
The UK regulator for Art Market Participants ("AMPs") is now visiting art fairs as well as conducting full interventions of regulated art businesses.Art fair visits If you've recently exhibited at...
Introducers vs. Intermediaries: Are you caught as a UK Art Market Participant?
Do you think that you - or a colleague, are not caught as an Art Market Participant ("AMP") because you or they are only acting as an introducer in transactions? If taking an active role, including...
How penalties are calculated for late registration as an Art Market Participant
A new financial reality for some Art Market Participant ("AMP") businesses in the UK is paying a penalty for late AMP registration with HMRC, the regulator. While unregistered businesses might want...
Publicly listed penalties: A new reality for late registration as an Art Market Participant (UK)
In April 2022, ArtAML was made aware that a gallery was receiving a penalty for late registration as an Art Market Participant ("AMP"). The gallery had only learned of anti-money laundering for the...
Register for or renew Anti-Money Laundering Supervision – and how to contact HMRC: for UK Art Market Participants
Wanting to register or renew for Money Laundering Supervision in the UK? Need to talk with HMRC as regulator for UK Art Market Participants? Read this post for key info. Points of note: >> The...
Do non-UK art businesses need to register for UK-based AML Supervision if transacting at art fairs?
Think that anti-money laundering that has hit the art sector doesn't apply to your business, as you're an overseas dealer presenting at a UK fair? Think again - including if you're based in the...
Simplified Due Diligence: An easy way to meet AML requirements?
If you’re subject to anti-money laundering (AML) legislation, you’re required to take steps that will raise red flags to signal the possibility of your business being the target of money laundering...
The Fountain Court Chambers Podcast: Fraud and Financial Crime in the Art Market
ArtAML CEO Susan J Mumford participated in this panel discussion about the current state of fraud and financial crime in the art market. A particular highlight of interest to art businesses is the...
HMRC’s message to Art Market Participants: Key changes in the updated BAMF Guidance (2022)
The British Art Market Federation (“BAMF”) Guidance was updated for UK Art Market Participants (“AMPs”) on 30th June 2022. HM Revenue & Customs (“HMRC”) as regulator sent an email update with...
Important changes to meaning of who is your ‘customer’ following BAMF Guidance Update (UK)
This article aims to update Art Market Participants ("AMPs") on key updates and clarifications, explain a shift in emphasis to take a risk-based approach and to overall help industry players...
How do you conduct AML at an art fair?
Before anti-money laundering became a reality for art businesses, ArtAML founders Susan J Mumford and Chris King were asking and addressing the question. Such events can be a crucial activity for...
What does the Luxury Goods Ban mean for the art market, including your business?
Luxury Goods Bans were introduced by multiple jurisdictions in the wake of the Russian invasion of Ukraine. Major art markets impacted include the US, UK, EU and Switzerland, all of which are...
Risk Assessment and AML Policy: A legal requirement for Art Market Participants
The original blog post dated 17th August 2021 was updated on 24th August 2022 to incorporate clarity provided in the updated BAMF Guidance (2022). In ArtAML's view, the intention of AML legislation...
The Art Law Podcast – Anti-Money Laundering Update: FinCEN’s Surprising Conclusion and the Impact of Russian Sanctions on the US Art Market
ArtAML Co-Founders Susan J Mumford and Dr Chris E King returned to the Art Law Podcast to discuss the surprise decision of FinCEN to not regulate AML in the art market (yet), and the immediate...
When will the U.S. art market be regulated for AML? The U.S. Treasury findings released: Study of the Facilitation of Money Laundering and Terror Finance Through the Trades in Works of Art
At last, the findings from the 2021 U.S. study on the potential application of anti-money laundering in the art sector have been published. This article accordingly highlights top-level insights...
What risks does the art market face of being the target of money laundering? Findings of the National Risk Assessment 2020 (UK)
An early attempt at highlighting vulnerabilities the art market faces of financial crimes was included in the National Risk Assessment 2020 (UK). ArtAML was involved as a key stakeholder, and we...
The Art Law Podcast: How AML Regulations are hitting the UK art market and how to comply
ArtAML Co-Founders Susan J Mumford and Dr Chris E King feature on the Art Law Podcast to discuss the recent roll-out of AML regulations in the UK. Speaking to The Art Law Podcast hosts Steve...
ArtAML’s responses to HM Treasurys’s consultations: Amendment to the Money Laundering Regulations and Call for Evidence for the Supervisory Regime
As a stakeholder for AML in the art market, ArtAML was invited to respond to two consultations with HM Treasury in autumn 2021 that look at developments in the Money Laundering Regulations as well...
ArtAML’s response to FinCEN’s Advanced Notice of Proposed Rulemaking: Anti-Money Laundering Regulations for Dealers in Antiquities
In September 2021, FinCEN issued an advance notice of proposed rulemaking (ANPR) to solicit public comment on the implementation of Section 6110 of the Anti-Money Laundering Act of 2020 (the AML...
Have your say: Two consultations set to impact the UK art market (deadline: 14th October 2021)
In July 2021, HM Treasury published two consultations that invite input from art market stakeholders. The following areas are covered: 'Digital art' being included in the definition of 'work of art'...
The Art Newspaper: Overseas AMPs are not immune to AML laws at UK fairs
Paula Trommel, deputy director of Corinth Consulting, directs a warning to overseas galleries and art advisors as activity in the London art market ramps up - via The Art Newspaper. As the industry...
Customer due diligence and reliance: Important clarity from HMRC to support your compliance
In June 2021, HMRC published risk guidance for the UK art market. Amongst other points, they outlined what is - and importantly isn't, intended by relying on other Art Market Participants (AMPs) in...
HMRC’s risk guidance for the art market: A must-read
HMRC as the UK's regulator for money laundering has published risk guidance. The findings are the result of getting to know specific situations faced by the industry. The publication presents two...
AML Training: A legal requirement for Art Market Participants
If you were thinking that reading AML guidance was enough to satisfy the requirement to have training, think again. Continuing to trade at the level of 10,000+ Euros as an Art Market Participant...
The Art Newspaper: Art world rushes to conform to UK’s anti-money laundering laws
Riah Pryor reports on HMRC registration progress by UK art market participants. She sought input from ArtAML CEO Susan J Mumford and Canvas Art Law Founder / Director Fionnuala Rogers. According to...
Might you (unknowingly) be an Art Market Participant?
There are many individuals dealing in art who don’t yet realise that they’re Art Market Participants (“AMPs”) according to the Money Laundering Regulations (UK). Some surprising yet frequent...
Own Art Interviews ArtAML CEO Susan J Mumford
Recently, we announced our collaboration with Own Art. Headed by Creative United and Hitachi Capital Consumer Finance, this interest-free payment scheme helps stimulate the market for contemporary...
Who needs to register as a ‘responsible person’ with HMRC?
Many Art Market Participants are being asked to register people in the business they didn't know were subject to the regulations. This screenshot from an Art Market Participant registration page on...
Artnet News Pro: Protecting Your Art Business Against Cybercrime
The notoriously tech-phobic art trade has found itself slap-bang in the middle of this digitally dominated 21st century. The pandemic, recent craze for NFTs, and a collector-base newly rich in...
Artists are not caught under AML in the UK
In June 2019, ArtAML Co-Founders Susan J Mumford and Dr. Chris King participated in the HM Treasury Consultation for the Transposition of the 5th Money Laundering Directive into UK law. In the...
‘Reliance’ isn’t enabling business as usual, so what’s the point?
One of the art market’s greatest concerns about anti-money laundering (AML) regulations is the potential loss of confidentiality surrounding clients. The obligation to reveal the identity of the...
So You Just Bought an NFT. Here’s What That May Mean for Your Taxes
What a difference a global sensation can make: 'NFTs' (non-tangible tokens) have gone from a relatively obscure acronym to a 24/7 obsession in the art world and beyond. While interested observers...
‘The Art Market – a Temporary Trend or an Investment Which Came to Stay?’: Niels Brabandt of The Leadership Podcast interviews Susan J Mumford
Our CEO and Co-Founder Susan J Mumford recently spoke with Niels Brabandt, owner of NB Networks, to shed some light on the inner workings of the art market. Tune into The Leadership Podcast ‘The Art...
How The New Anti-Money Laundering Laws Will Affect Art Collectors
Hot on the heels of the implementation of AMLD5 and AMLD6 across the EU and UK, January 2021 saw the U.S. House and Senate vote through a bill to extend the rules of the 1970 Bank Secrecy Act to...
UK Art Dealers Are Misusing the Law to Avoid New Money-Laundering Regulations
In recent weeks it has come to light that some art businesses may have misunderstood, and unknowingly be breaking, a key part of the latest anti-money laundering regulations. We were therefore more...
Antiques Trade Gazette letter to the editor: No need to panic about anti money laundering rules
The art market has been dealing with a swathe of changes ranging from Brexit to anti-money laundering. In this letter by our CEO Susan J Mumford, she takes three recent breaking news items and...
Understanding your AML obligations, and how technology saves time and money: ArtTactic podcast interview with ArtAML
We're delighted to have been interviewed for ArtTactic’s podcast series. Taking place prior to the passing of the National Defense Authorization Act 2021 (US), Podcast Host interviewed ArtAML CEO...
Spotting fake IDs: A new reality for the art market?
We frequently hear art market participants ask if money laundering is really an issue for the industry. While it’s still early days for the implementation of the 5th Money Laundering Directive that...
How to get AML-ready as an Art Market Participant
Following the announcement that UK Art Market Participants have been given until 10th June 2021 to register with HMRC, what can you do to get ready? See tips below from the ArtAML Team. Be sure to...
Art Market Participant Registration (UK) deadline extended to 10th June 2021
The Government is to push back the deadline for businesses to register under the new Anti-Money Laundering (AML) regulations from January 10 to June 10 next year. The five-month delay comes in the...
Artnet News feature: ‘A New App Aims to Help UK Art Dealers Struggling to Comply With the Country’s Confusing New Anti-Money-Laundering Rules’
We've been delighted to partner with Artnet News on the beta launch of our Customer Due Diligence platform, which is now steaming ahead towards the 1st September public launch. Associate Editor...
Guide for Registering as a UK Art Market Participant
In order to carry out activities as an Art Market Participant in the UK, you need to register with HMRC. This is akin to an application process, as it is possible to be rejected. This has been...
ArtAML’s response to HM Treasury’s Consultation with industry: Transposition of the Fifth Money Laundering Directive
In late Spring 2019, HM Treasury, as the UK governmental authority tasked with drafting legislation to implement the EU's Fifth Money Laundering Directive with a deadline of 10th January 2020,...
A visual guide to AML for the art market – for Private Sales
Keen to have a handy guide for AML in the art market? Our publication 'How well do you know your clients? A visual guide to anti-money laundering for the art market for Private Sales' does just...
How should the art market comply with the new AML legislation?
The amendments to UK legislation implementing the 5th Anti-Money Laundering Directive were passed in UK Parliament on 20th December 2019 and took effect on 10th January 2020. At the time of writing,...
Art Market Participants: What you need to know – webinars by HMRC
HMRC as the regulator for UK Art Market Participants runs webinars that are specific to the sector as well as more generally for AMP businesses. Press play on the image below to watch a webinar for...
Anti-money laundering legislation could hit the US art market
On 22nd October 2019, the US House of Representatives passed HR 2514, also known as the 'Counter Act'. If it passes the Senate and becomes law, the result will be anti-money laundering legislation...
Chinese whispers and the AML legislation hitting the art market
What’s YOUR interpretation of new laws requiring art dealers to conduct CDD checks on collectors? When speaking with art dealers at fairs, we’ve found that while many haven’t yet come across the...
Transparency and advisors: AML’s cultural impact on the art market
Privacy has been established as a way of conducting business in the art market over a period of many decades. The very culture of a gallery not knowing the identity of a buyer as an intermediary (or...
Is art really used to launder illegally obtained funds?
In short, yes. Why? Ease of transport: Art is relatively easy to move. Buy a piece, transfer it across a border and sell it for a lot more than that for which it was acquired. Price flexibility is...
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