Deadline approaching for Art Market Participants to register with HMRC

Nicola Finnerty

The 5th Anti-Money Laundering Directive (AMLD5) came into force in January 2020 and extended current anti-money laundering legal framework to cover business activities taking place within the art market.

The directive requires art market participants (AMPs) - galleries, auction houses, dealers and individual artists - involved in selling work directly to clients through single or linked transactions with the sale of goods in excess of €10,000 (c.£8.5k) to conduct due diligence, monitoring, and enhanced record keeping. Although AMLD5 came into law in the UK over a year ago, the deadline for registering with HMRC as an AMP was extended to 10 June 2021 to take account of the disruption being faced by the industry as a result of the COVID-19 pandemic.

A training programme was developed and delivered by Creative United in partnership with Kingsley Napley where free training sessions and workshops took place offering practical advice to support art market participants to understand, assess and respond to their obligations.

In this podcast, Nicola Finnerty, (Partner) & Leena Lakhani, (Associate, Barrister) in our Criminal Litigation team, provide an insight on the registration requirement and explore the following issues: 

  • Who in the art world needs to register with HMRC for Anti-Money Laundering Supervision?
  • What is the definition of an AMP?
  • What does the term linked transaction mean?
  • What is the purpose of registration and how does the process actually work?
  • What are the consequences of failing to register and continuing to trade after the deadline has passed?

Further information

For further information on the issues raised in this podcast, please contact a member of our criminal litigation team.


About the authors

Nicola Finnerty is a Partner in the Criminal Litigation team and is a leading criminal defence expert in both business and general crime. She has experience of fraud, corruption  (including the Bribery Act) and cartel matters, financial compliance, money laundering, asset seizure and confiscation cases, through to sexual offence cases, drugs, murder and offensive weapon crimes. Nicola has acted for many high profile individuals who have needed advice on criminal matters. She has also represented corporate clients, financial institutions and professional firms in investigations and proceedings brought by the SFO, CPS, FCA, HMRC and other prosecuting bodies. She is routinely instructed in judicial review and appeal cases.

Leena Lakhani is a Barrister in the Criminal Litigation team. Her practice covers all areas of criminal defencewhite collar crime and internal investigations. She regularly acts in cases of serious fraudbribery and corruption and money laundering brought by the Serious Fraud Office (SFO), HM Revenue & Customs (HMRC) and Serious Fraud Division (SFD) of the Crown Prosecution Service. She has a particular interest in matters involving the breach of Anti-Money Laundering Regulations.


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