Sanctions screening
99p a personEach person or company against the UK, UN, EU and US (OFAC) lists, refreshed daily. A possible match shows the listing beside your details.
Why: OFSI reporting dutyFor galleries, dealers, auction houses and advisers
Every work has a provenance. So should every buyer.
Money-laundering and sanctions checks on buyers and sellers in any art sale of £10,000 or more, with one signed certificate for your file.
£1.39a person: the UK, UN, EU and US sanctions lists, PEP and adverse media. ID and risk records and six weeks of monitoring included.
No subscription, credit from £5Official lists, refreshed dailyRecords kept at least five years
The rules
Four things to know first
£10,000
A sale of a work of art worth £10,000 or more, or linked payments or works adding up to it, brings in the money-laundering rules. It was 10,000 euros until 30 June 2026.
Source: MLR 2017, regulations 14 and 27 (opens in a new tab)14 May 2025
Since then art market participants have been "relevant firms": tell OFSI as soon as practicable if you know or suspect a customer is sanctioned.
Source: OFSI guidance for art market participants (opens in a new tab)Register first
Register with HMRC before you trade as an art market participant. Trading while not registered is a criminal offence.
Source: GOV.UK: who needs to register (opens in a new tab)6 months
Not reporting to OFSI when you should is an offence: up to six months in prison, a fine, or both.
Source: OFSI guidance for art market participants (opens in a new tab)In scope?
Is this sale in scope?
Pick what you do and enter the price. You'll see who to check, when, and what the checks cost.
In scope
£48,000 is covered by the money-laundering rules
Customer due diligence applies, and the duty to report a sanctioned customer to OFSI.
Who to check
- The buyer
- Anyone buying on the buyer's behalf
- For a company or trust: the people who own or control it
When
Before the sale goes through.
£1.39for the buyer: sanctions, PEP and adverse media. Records and six weeks of monitoring included.
Start an art sale check Sources: MLR 2017, regulation 14 · regulation 27 · regulation 30 · British Art Market Federation guidance
What's included
Every check in an art sale
Seven parts, one job, one certificate. The checks the law requires are ticked for you.
PEP and adverse media
40p a personIs the person politically exposed, or close to someone who is? Is there serious adverse news? Required for every customer where the money-laundering rules apply.
Why: MLR 2017, regulation 35Company and owners
£4.38 + 40p a personA company buying or selling: its Companies House record, every director and the owners through each layer of holding companies (up to 30 people), all screened, then checked for PEP.
Why: MLR 2017, regulation 28ID record
IncludedYou check the passport or ID card. Certaby records which document you saw, its number, who checked it and when, and puts it on the certificate.
Why: MLR 2017, regulation 28Risk and source of funds
IncludedWhere the buyer lives, why they're buying and where the money comes from, with a risk rating. A PEP, a high-risk country or cash asks for enhanced checks and evidence.
Why: MLR 2017, regulations 28 and 33Monitoring
6 weeks includedEveryone in the sale is checked every day against new sanctions listings, with an email if one appears. Extend from the job at 10p a person a week if the sale runs longer.
Why: MLR 2017, regulation 28(11)The certificate
IncludedEvery check, the lists and their dates, signed and dated, with a link anyone can open to verify it. Kept for at least five years.
Why: MLR 2017, regulation 40Seven checks, one job
Open a job for the sale: the checks the law requires are already ticked, and you see the price before anything runs.
Start a checkA sale, start to finish
Watch the provenance paint itself
A painting sold on commission to a private buyer. Scroll, and each step lands on the same file.
- 01The owner asks you to sell
Check the consignor
You act for them and earn a commission, so they're your customer. Open a job for the sale, add them, and their sanctions, PEP and adverse media checks run in seconds. Record the ID you saw.
£1.39 - 02A buyer comes forward
Check the buyer, and anyone buying for them
Add them to the same job before the sale goes through. Only the new person is charged. Buying through a company? Add the company, and its directors and owners are found and screened.
£1.39 - 03The price is agreed
Record where the money comes from
Note what the buyer told you about the money and why they're buying. A PEP, a high-risk country or a cash payment asks for enhanced checks and the evidence before the record reads complete.
Included - 04Payment arrives
Note who paid
Record that the money came from an account in the buyer's own name, or who else paid and why. Someone else paying becomes part of the sale: add them and check them too.
Included - 05The work leaves the gallery
Sold, with one certificate
The certificate lists every check with the dates of the lists used, and a link anyone can open to verify it. Both people stay on the daily sanctions watch for six weeks.
Certificate issued
Prices
Admit one. No subscription.
Add credit from £5 and pay for each check as you run it. You see the exact price before anything runs.
Admit one
Lot 1
A private buyer
Sanctions, PEP and adverse media on one person. The ID record, the risk and source of funds record and six weeks of monitoring are included.
£1.39a person
Admit two
Lot 2
Buyer and seller
Both sides of a sale on commission or at auction, on one certificate. Add bidders or anyone paying for the buyer at the same price each.
£2.78for the two
Company
Lot 3
A buyer through a UK company
The company screened with PEP and adverse media, its Companies House record, directors and owners through each layer, all screened. Then 40p for each director and owner checked for PEP.
£4.38+ 40p a person found
Box office
Work out a sale with the same sums the checkout uses.
PeopleBuyers, sellers, anyone paying
UK companiesBuying or selling
Directors and ownersPer company, found for you
This sale£2.78
2 people × £1.39
After the six included weeks, monitoring is 10p a person a week, up to a year. Check often? Membership starts at £24 a month.
Buyers from anywhere
Art travels. So do the checks.
Four lists, worldwide
The UK, UN, EU and US lists name people and companies from every continent. Names are matched across common spellings, so Muhammad finds Mohammed and Mohamed.
High-risk countries flagged
Someone living in North Korea, Iran or Myanmar, or a company set up there, needs enhanced checks by law. Countries on the FATF grey list count as a risk factor. Certaby flags both.
Companies registered abroad
Certaby reads Companies House. For a company registered elsewhere, add the people who own and control it, and each is screened like any buyer.
The ID you saw, on file
Check the passport yourself, wherever it was issued. Certaby records the document, who checked it and when, on the certificate.
Certificate of checksArt sale · oil on canvas · £48,000
| Consignor: sanctions, 4 lists | Clear |
|---|---|
| Consignor: PEP and adverse media | No match |
| Buyer: sanctions, 4 lists | Clear |
| Buyer: PEP and adverse media | No match |
| ID documents | 2 recorded |
| Source of funds | Recorded · standard risk |
| Monitoring | Daily, six weeks |
certaby.com/verify/7f3a9c…
The certificate
Certificate of authenticity
Not for the painting: for your checks. One page that shows what you did, when, and against which lists.
- Every check, the lists used and their dates, the records and who made them, signed and dated.
- A link anyone can open to confirm it's genuine, with no account needed.
- Kept for at least five years after the sale, as the law asks, and yours to download at any time.
- Issued again when you record a later step, so the file always matches what you did.
Questions
What art businesses ask us
Am I an art market participant?
You are if, as a business, you trade in works of art or act as an intermediary in buying or selling them, and a sale (or linked sales) is worth £10,000 or more. A freeport operator storing works of art worth £10,000 or more for a person is one too.
Selling work you made yourself doesn't count. The threshold was 10,000 euros until 30 June 2026.
Do I need to check the seller as well as the buyer?
Often, yes. At auction, HMRC expects both the seller who consigned the lot and the buyer to be checked. The industry guidance approved by HM Treasury covers the buyer and anyone acting for them, and the seller where you provide a service to them and are paid for it, as when you sell on commission.
HMRC: auction houses (opens in a new tab) · British Art Market Federation guidance (opens in a new tab)
When do the checks have to be done?
Before the sale goes through. At auction, HMRC expects the buyer to be checked before the work is released, and the seller (and registered bidders, where reasonable) before the auction when the estimate is £10,000 or more. The value counts the hammer price with taxes, fees and commission.
MLR 2017, regulation 30 (opens in a new tab) · HMRC: auction houses (opens in a new tab)
What if a buyer matches a sanctions list?
Certaby shows the possible match with the listing, so you can compare details such as date of birth and nationality. If you know or suspect the person is designated, stop the sale, freeze anything you hold for them and report to OFSI as soon as practicable.
OFSI guidance for art market participants (opens in a new tab)
Does Certaby register me with HMRC?
No. You register with HMRC yourself, before you trade: £400 a year for each of your premises, plus £40 for each person HMRC approval-checks. Once you're registered, Certaby keeps the records HMRC asks to see.
A buyer is paying in instalments. Does that count?
Yes. Payments that are linked, or several works bought together, count as one sale. If they add up to £10,000 or more, the checks apply.
Is there a subscription?
No. Add credit from £5 and pay for each check as you run it. If you check often, membership starts at £24 a month.
Sell the work.
Keep the proof.
Open your first art sale in a few minutes. The checks the law asks for are already ticked, and you see the price before anything runs.
Sources
- MLR 2017, regulation 14: art market participants (£10,000 since 30 June 2026, SI 2026/621) (opens in a new tab)
- MLR 2017, regulation 27(7C): when an art market participant applies customer due diligence (opens in a new tab)
- MLR 2017, regulation 30: verification before the transaction (opens in a new tab)
- MLR 2017, regulation 40: record keeping (opens in a new tab)
- OFSI: financial sanctions guidance for high value dealers and art market participants (opens in a new tab)
- HMRC: auction houses, what we expect to see (ECSH54700) (opens in a new tab)
- HMRC: art market guidance now published by the British Art Market Federation (opens in a new tab)
- GOV.UK: who needs to register for money laundering supervision (opens in a new tab)
- HMRC: registration fees (opens in a new tab)