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 provides important insight (see more tips below):

Who you need to register - HMRC screenshot

What this means:
>> If you have a Company Director who is not active in the day-to-day AML and/or business operations, they need to be registered as a responsible person.
>> The official Company Secretary with Companies House – if you have appointed one, will need to be registered.
>> Whatever the business structure, anyone who owns more than 25% is an Ultimate Beneficial Owner and needs to register.
>> All team members involved in AML operations need to register.

Who doesn’t need to register?
>> Owners (who are not Directors / Secretaries) that own less than 25% of the business.
>> Team members who are not involved in AML operations and who are not senior managers of activities covered by the ML Regulations.