HMRC’s 2025 Risk Assessment for the art market: What’s new and what AMPs must now do

September 30, 2025
by ArtAML™ Team

HMRC’s latest update to its art market risk guidance, now renamed to a risk assessment (‘Understanding money laundering risks and taking action for art market participants’) represents a pivotal moment for compliance in the sector. Here’s what’s new, why it matters and how to respond.

From advisory to regulatory expectation:

The 2021 guidance was primarily explanatory, helping newly regulated AMPs understand the risks in the art market and the basics of compliance under the Money Laundering Regulations (MLRs). The 2025 edition takes a far firmer stance. It is now explicitly described as an HMRC risk assessment issued under Regulations 17 and 47 of the MLRs, meaning that AMPs must take this assessment into account when developing their own business-wide risk assessments.

HMRC now requires AMPs to keep a written and up-to-date risk assessment, review it whenever business models, clients, or transaction methods change and provide a copy to HMRC upon request. What was once best practice is now a clear regulatory expectation of demonstrable compliance.

Revised risk ratings and emerging threats: 

HMRC has reclassified the money laundering risk for AMPs from ‘high’ to ‘medium,’ reflecting improved supervision and better understanding of the market. Nonetheless, the sector remains vulnerable to criminal misuse because of high-value, cross-border and private transactions. The 2025 guidance highlights several emerging threats:

  • Crypto-asset payments, flagged as high risk due to anonymity and traceability issues.
  • Art price manipulation used to disguise or move illicit value.
  • Intermediary sales and remote transactions that obscure beneficial ownership.

Terrorist financing remains low risk, but the guidance references two UK-linked AMP cases since 2020, suggesting the issue may be underreported.

New – proliferation financing and sanctions obligations:

A major addition to the 2025 guidance is the inclusion of proliferation financing (PF): this is the provision of funds or financial services used to develop, acquire, or distribute nuclear, chemical, or biological weapons and related materials, in violation of national or international law. AMPs are now required to consider PF as part of their AML risk assessment and to screen clients and transactions against the UK Sanctions List. HMRC specifically identifies Iran, North Korea, Russia, and Syria as key jurisdictions of concern.

Reinforcing SAR and record-keeping requirements:

The new guidance explicitly requires AMPs to file Suspicious Activity Reports (SARs) to the National Crime Agency as soon as a suspicion arises. It reinforces that risk assessments, policies, and procedures must be written, reviewed and updated in line with changes to business operations.

Our business-wide AML risk assessments already address these requirements: 

The risk factors and emerging threats outlined in HMRC’s 2025 guidance are not new to ArtAML™ clients. Our business-wide AML risk assessments have already been covering all of these points, including crypto-asset risks, sanctions screening and the five core risk factors mandated by HMRC. We have been further developing our risk assessment approach to make these new regulatory requirements explicit and ensure full alignment with HMRC’s updated expectations.

This is a clear example of how the AML compliance landscape is continually evolving. As Key Stakeholders in the sector, we closely monitor regulatory developments to ensure our clients remain compliant as requirements shift. Our business-wide risk assessments are accompanied by a corresponding AML Policy that includes detailed policies, controls and procedures tailored to each AMP’s business model.

For a detailed breakdown of what must be included in an AMP’s business-wide risk assessment, see our Knowledge Base article via https://knowledgebase.artaml.com/hmrcs-2025-risk-assessment-what-uk-amps-must-include-in-a-business-wide-aml-risk-assessment .

In conclusion

The 2025 guidance marks a maturing phase in AML regulation for the UK art market. HMRC now expects AMPs to move beyond awareness and towards full, evidenced compliance. Risk assessments must be comprehensive, documented and reflective of current threats – including crypto exposure, sanctions and proliferation financing.

If you would like support in developing or updating your business-wide risk assessment, get in touch with our Compliance Team.

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