Art AML Compliance

Specialist AML & Due Diligence Consultancy for UK Art Market Participants

Art market AML compliance made simple. Codex Compliance helps galleries, dealers, and other art market participants manage KYC, customer due diligence, beneficial ownership checks, and record keeping with a clear, risk-based workflow designed for the UK art market.

If you're an art gallery, dealer, or advisor involved in high-value transactions (over €10,000 (approx. £8500) in a single or multiple transactions to the same customer), you're subject to the UK's anti-money laundering regulations.

Common questions

What is art market AML?

1

Art market AML (Anti-Money Laundering) are UK rules requiring galleries, dealers, and auction houses to check clients and transactions to stop criminals using art to hide dirty money. It covers customer due diligence, identity checks, and reporting suspicious activity to stay compliant with HMRC regulations.

Do galleries need AML compliance?

2

Yes, UK art galleries qualify as art market participants (AMPs) if they trade works of art worth €10,000+ (about £8,500). You must register with HMRC, do KYC checks, and follow AML rules- even for private sales or intermediaries.

What checks are required?

3

Art dealers must verify client identity (name, address, DOB), screen for sanctions/PEPs, check beneficial ownership for companies/trusts, confirm source of funds, and assess transaction risk before deals hit €10,000.

What is customer due diligence in the art market?

4

Customer due diligence (CDD) means identifying who you’re really dealing with individuals, companies, or trusts, before completing an art sale. For art market transactions over €10,000, collect ID, verify it, and understand the buyer’s purpose and funds source.

When do you need enhanced due diligence?

5

Enhanced due diligence (EDD) is required for high-risk cases: PEPs (politically exposed persons), high-risk countries (where corruption is high or bank AML controls are lax), payments from third parties, complex ownership, cash deals, or buyers avoiding ID checks.

What records do art galleries need to keep?

6

Art galleries must retain CDD evidence (ID copies, risk assessments, transaction details) for 5 years minimum. Keep everything organised for HMRC audits - digital or paper works, but it must be accessible.

How do I check beneficial ownership?

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For companies/trusts, identify who owns/controls ≥25% or has significant influence. Get shareholder registers, trust deeds, or UBO declarations. Cross reference with public records or databases - don’t worry we can do that for you.

What counts as a suspicious transaction in art sales?

8

Red flags include but aren’t limited to: third-party payments, rapid buy-sell flips, buyers using shell companies, refusing ID, a fake moustache, mismatched funds source, or art valued way above/below market.

Our Services

  • Book a free consultation to discuss your AML needs. We’ll review your business risks, identify potential gaps, and provide actionable next steps with no obligation.

  • Comprehensive business-wide risk assessments designed for Art Market Participants and other regulated businesses. We assess vulnerabilities, compliance gaps, and exposure to financial crime, giving you a clear roadmap to strengthen controls.

  • We create bespoke AML policies and procedures, ensuring your business meets regulatory obligations while protecting against money laundering risks. Clear, practical, and easy to implement.

  • Tailored AML Training for art galleries, dealers, and businesses. We provide practical workshops that cover customer due diligence, red flags, and regulatory requirements, helping your team stay compliant and confident.

  • Providing various levels of due diligence for individual customers or package deals, from simple know your customers checks to enhanced investigations (for PEPs, high-risk jurisdictions, complex ownership, source of funds/wealth).

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