The UK art market is facing a notable escalation in anti-money laundering (AML) enforcement, as the latest round of HM Revenue & Customs (HMRC) penalties signals a shift from punishing simple registration failures to more deeply scrutinising operational compliance.
On 10 July, HMRC published the latest round of fines issued to Art Market Participants (defined as “a company or sole practitioner who trades in or acts as an intermediary in the buying or selling of works of art where the transaction value, or a series of linked transactions, is €10,000 or more”) . The list revealed a hefty £158,679 fine to DYS44 Art Gallery Limited. Based in London, the gallery was fined for wide-ranging procedural failures, including “[not] carrying out risk assessments, having the correct policies, controls and procedures, appropriate staff training, conducting due diligence, timing verification, and record keeping”.
DYS44’s director, Cesare Lampronti, tells The Art Newspaper: “I have taken significant steps to correct this concerning and unusual situation to be sure the gallery is fully compliant with HMRC regulatory developments.” The gallery received the fine for formal procedures rather than any suggestion of engagement with illicit activity. He adds: “Although no excuse, my more than than 60 years of experience and personal level of confidence in the integrity of the collectors and art market participants with whom I work, contributed to my assessment that the gallery was operating a low-risk business.”
The latest release of figures covers the period between 1 October 2024 and 31 March 2025. Rena Neville, the founder and director of AML specialists Corinth Consulting, says “the number of penalties being issued is accelerating. Compare the over 80 penalties listed for the most recent six-month period with the 61 penalties issued for the 20 months from January 2021 to September 2023.”
While most of the sanctions still relate to firms failing to register in time with HMRC, this latest update reveals cases where the breaches go beyond this oversight. Edward Burdett, trading as Atlas Gallery, for example, was fined £28,500 for failing to notify HMRC of “material changes in business circumstances”. A spokesperson for the gallery declined to comment.
A spokesperson for HMRC says: “Non-compliance is serious, and penalties reflect this. Compliance goes beyond registration and requires robust systems and controls to prevent criminal abuse.” They add that HMRC continues to “work with stakeholders and representatives across all sectors we supervise, including the art market, to raise awareness of their responsibilities under the regulations”.
The scale of fines is also rising. The average registration fines for the January to September 2024 period stood above £3,000 and reached £13,000 at the top end. This latest batch of figures reveals an average fine of over £6,900, several fines around £23,000, and a highest figure of over £150,000. Even the smallest non-registration penalties now exceed £1,200, with very few below that.
Check, and recheck, customers
Tom Noon, a co-founder and chief executive of the art market due diligence firm Arcarta, highlights the growing complexity of obligations: “As regulations develop, and as sanctions regimes tighten, the requirement for ongoing monitoring becomes even more important. Put simply, Art Market Participants need to ensure that they have a process in place that allows them to ‘rerun’ checks on their customers more than once, and routinely as their customers continue to conduct business with them.” He adds that while some multi-national participants refresh their CDD (customer due diligence) information every 12 months, as a general rule, it is practical that evidence of due diligence is refreshed as a minimum every three months or sooner “depending upon how risky a customer appears to be”.
Paul Hewitt, the director general of the Society of London Art Dealers says: “[The fines] continue to be a sensitive area, particularly on ‘technical’ breaches, for example of not reporting changes in an AML officer or a change of address within a given timeframe. The headline is of fines being issued with the implication that AMPs are committing money laundering offences, whereas the reality [is that] they are often frustrated by the administrative burden (and cost) of annual registration/reregistration, which serves little purpose other than revenue generation for HMRC.”
Hewitt does note that the latest National Risk Register Assessment by the National Crime Agency, which reduced the risk rating for art, is a welcome sign that the agency is listening to the concerns of the trade.
Nevertheless, with the rate and breadth of fines increasing, it is clear that HMRC is no longer content simply to pull businesses into the regulated perimeter. Increasingly, it is testing whether they are actively managing AML risk in line with expectations.
