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Art market · galleries, dealers and auction houses

Checks for every saleof £10,000 or more.

Check the buyer and the seller before a work changes hands, watch them after, and keep the record HMRC asks to see.

Start from £9 a month Your duties
£10,000
A sale, or linked sales, that brings in the rules (since 30 June 2026)
Medium
Money laundering risk in the art market (NRA 2025)
OFSI
Sanctions reporting duty since 14 May 2025
01 · Your duties

What the rules ask, and what we do.

From the Money Laundering Regulations 2017, HMRC’s handbook and the art market guidance approved by HM Treasury.

  1. 01Regs 14(1)(d), 27(7C)

    Know when the rules apply

    A sale of a work of art, or linked sales, worth £10,000 or more, and storing art worth that much in a freeport. The value includes taxes, fees and commission.

    You decide when a sale is in scope. Stratum keeps the checks and the record for each person you add.

  2. 02Regs 28, 30 · HMRC ECSH54700

    Check the buyer and the seller

    Identify and verify your customers before the sale completes. At auction, check the seller when the consignment is agreed and the buyer before the work is released.

    Add each buyer or seller, a person or a company, and check them in one run. A company comes with its owners and directors from Companies House. Their ID with a live selfie, by link, through Vouchsafe (on the GOV.UK register of certified services).

  3. 03Regs 28(4), 30A

    Find who is really buying

    Where a company or trust buys or sells, identify who owns or controls it. Sales through intermediaries can hide the true buyer.

    Owners traced to people from Companies House, and confirmed by your client through their details link.

  4. 04Regs 33, 35 · sanctions rules

    Screen for sanctions and PEPs

    Enhanced checks for politically exposed persons. Since 14 May 2025 you must tell OFSI as soon as practicable if you know or suspect a customer is designated.

    UK, UN, EU and US lists and PEPs for each buyer, seller and the people behind them. You decide each possible match, with a reason.

  5. 05Reg 28(11)

    Keep watching

    Monitor ongoing relationships with collectors and consignors, and look again when their circumstances change.

    Each checked client re-screened against the sanctions lists every morning, with changes at Companies House picked up.

  6. 06Regs 18, 19, 40

    Your risk assessment and records

    A written firm-wide risk assessment with policies that follow from it, and due diligence records kept for five years.

    Every check, decision and document kept, with an audit trail and an inspection bundle. Soon A risk assessment and policies written for the art market.

02 · Checks

What we check for the art market.

Every check in every plan. Yours are lit; pick another industry to compare.

9 of 17 checks for the art market
People3
ID and livenessBy phone link
Proof of addressDocument check
Soon
SanctionsUK, UN, EU, US
PEPPolitically exposed
Companies2
Company profileCompanies House
OwnersTraced to people
Directors' IDVerified or due
Disqualified directorsOfficial register
FCA registerAuthorised firms
InsolvencyStatus and history
Risk scoreA to F, with reasons
Trade0
US export listsEntity List and 5 more
50% ownershipListed owners
Shipment recordEvery party
Always included4
Daily monitoringEvery checked client
Signed certificateWith a verify link
Audit trailEvery action
APIREST and MCP
03 · Where the risk is

Where the risk is.

The 2025 National Risk Assessment rates money laundering risk in the art market as medium, down from high. It names these vulnerabilities.

  • Sales through intermediaries that hide the buyer
  • Private sales
  • Works priced above or below their value
  • Payment in cryptoassets
  • Buyers and sellers overseas
  • Art fairs with buyers from less regulated markets
  • Anonymous or layered companies
  • Art moved across borders to shift value

Source: HM Treasury, National Risk Assessment 2025, paragraphs 5.135 to 5.145

04 · Questions

Asked by galleries and dealers.

Am I an art market participant?

Yes 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 come to £10,000 or more; or you run a freeport storing art worth that much for someone (regulation 14(1)(d)). Selling work made by one of your own members doesn’t count. The threshold was 10,000 euros until 30 June 2026.

Do we check the seller as well as the buyer?

Often, yes. HMRC expects an auction house to check both the seller and the buyer when a sale is in scope, and registered bidders where that is reasonable.

When must the checks be done?

Before the sale completes. At auction: the seller when the consignment is agreed, the buyer before the work is released. If a bid unexpectedly takes a sale to £10,000 or more, check both as soon as possible.

What counts towards the £10,000?

The price with taxes, fees and commission, and linked payments or works bought together. HMRC’s example: an £8,000 hammer price with 20% VAT and 10% commission comes to £10,400.

What if a buyer is on a sanctions list?

Stop dealing with them, freeze anything you hold for them, and tell OFSI as soon as practicable. A company more than 50% owned or controlled by a designated person is treated as designated too.

Who supervises us?

HM Revenue and Customs. You register before you trade: £400 for each of your premises, and £40 for each person HMRC checks. The industry’s guidance, approved by HM Treasury, is published by the British Art Market Federation.

Does Stratum register us with HMRC?

No. You register with HMRC yourself. Stratum keeps the checks, decisions and records HMRC asks to see.

Start with your next sale.

Add the buyer and the seller and run their checks: each is then watched every morning, with a reminder to check them again each year.

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