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. Finally published on 7th February, the Guidance is substantial at 111 pages.

 

Too long to read?
Rest assured, terms of the Guidance are incorporated into the ArtAML solution, to support you to comply with confidence. It is however important that you actively learn about this obligation of AMPs and not only have AML training, but also document it.

 

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:

 

Front page of BAMF Guidance. Black text on white page with black border

 

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[1] See http://www.legislation.gov.uk/uksi/2019/1511/contents/made