How to get AML-ready as an Art Market Participant

September 2, 2020
by ArtAML™ Team

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 note that the legislation is in force. To get support with secure and remote document uploads by your clients, ID verification, PEP and Sanctions checks and more, complete an ArtAML platform expression of interest.

Here are some ways that you can continue to prepare:

 –      Focus on a ‘risk-based approach’. Compliance is not a box-ticking exercise: it’s about developing a way of thinking. Dedicated technology can walk you through the process, saving time and prompting risk-based considerations. Training is important for you and your staff (and you will be asked about this when registering).

–      Conduct your business’s AML risk assessment and create a corresponding AML Policy (aka ‘policies, controls and procedures’). This will both help compliance now and prepare you for your AMP (Art Market Participant) registration.

–      Start keeping records. This includes documentation showing you have conducted training (as above), as well as any AML checks you have undertaken for qualifying transactions of 10,000+ Euros. Associated records must be kept for a minimum of five years after the completion of transactions. Include notes on why you made decisions on whether or not to transact with entities, particularly where you’re unsure. This could prove to be vital for future investigations.

–      Set up secure storage. This will help you meet GDPR requirements and protect sensitive personal information about customers. The new AML law introduces a level of transparency to a transaction, but this is separate from privacy or confidentiality considerations. 

–      Back up records in two ways. Use the cloud and a physical external hard drive, all securely encrypted.

–      Review your ability to assess people in AML checks. Your business relies upon you socialising and assessing people. How good are you at this now and what do you need to do to reduce risk further on this point? How easily can you spot ‘red flags’?

–      Start educating buyers now. Get those you transact with used to the idea of AML compliance now. As you sell pieces and arrange deals, explain what you need and why you need it.


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