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 attempts to resume to its pre-pandemic glory with the return of in person art fairs, including Frieze London, Frieze Masters and the 1-54 Contemporary African Art Fair, non-UK galleries and art advisors should heed warning.

Since the imposition of the EU’s Fifth AML Directive, overseas exhibitors are not immune to the stringent new Anti-Money Laundering (AML) regulations.

What action should be taken by non-UK based dealers and galleries attending art fairs in the most heavily regulated country in the Europe?

• Get in touch with HMRC (as the regulator for AMPs in the UK) to see if they need to register as an Art Market Participant.
• Regardless of needing to register, AMPs that fall into scope will be expected to:
  • Conduct AML checks for qualifying transactions that take place in the UK.
  • Provide AML training (with certification) to all staff who will be involved with AML for UK transactions.
  • Have conducted an AML risk assessment, with corresponding AML Policy, (containing policies, controls & procedures) for their own business, to help know what risks they’ll typically need to be aware of and address (in addition to any other risks that are highlighted when conducting AML checks).

Read the full piece, published August 20th 2021, in The Art Newspaper.

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