Do art dealers have to do AML and sanctions checks on buyers?

Yes, on any sale (or linked sales) worth £10,000 or more. A business that trades in works of art or acts as an intermediary in buying or selling them is an "art market participant" under the Money Laundering Regulations 2017 (regulation 14), and so is a freeport operator storing works of art worth £10,000 or more for a person. The threshold was 10,000 euros until 30 June 2026. Selling work you made yourself doesn't count.

Who to check. The buyer and anyone acting for them. The seller too where you provide a service to them and are paid for it, as when you sell on commission; at auction HMRC expects both the consignor and the buyer to be checked.

When. Before the sale goes through (regulations 27 and 30). 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, and instalments or several works bought together count as one sale.

What. Identify and verify the person, and for a company the people who own or control it; find out whether they are a politically exposed person; assess the risk, and check the source of funds where it is high. Keep the records for five years (regulation 40).

Sanctions. Art market participants are "relevant firms" under UK financial sanctions: if you know or suspect a buyer or seller is a designated person, stop the sale, freeze anything you hold for them and report to OFSI as soon as practicable. Screening each party against the UK Sanctions List, and the UN, EU and US lists for international clients, is how you would know.

Registration. Register with HMRC for money-laundering supervision before you trade: £400 a year for each of your premises, plus £40 for each person HMRC approval-checks.

On Certaby each buyer or seller is £1.39: the UK, UN, EU and US sanctions lists with PEP and adverse media, with the ID and risk records and the first 6 weeks of monitoring included, on one signed certificate for the sale.

Source: The Money Laundering Regulations 2017, regulation 14 (art market participants)

Last updated 2026-10-09.