AML and the art market: HMRC data on enforcement and key takeaways

HMRC continues to pursue enforcement action for breaches of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the “MLRs”).

Data published in February 2026 illustrates the latest action HMRC has taken against AMPs.

The Treasury AML Supervision Report published in December 2025 also showed significant increases in formal and informal actions HMRC has taken in 2024/25 as against 2023/24.

This short article highlights the key data points and takeaways for the art market.

Data published by HMRC on 9 February 2026

Data published by HMRC on 9 February 2026 reveals fines HMRC has issued against AMPs. This data shows:

HMRC issued 335 penalty notices in the period 1 April 2025 to 30 September 2025 for breaches of the MLRs.
Art Market Participants (“AMPs”) were the third most fined sector in this period, behind estate agency businesses and accountancy service providers.
35 fines were published against AMPs in total, with all but one of these fines being for a breach of Regulation 56 (failure to register at the required time).
The sole fine for AMPs that was not for a breach of Regulation 56 was a £5,000 fine for a breach of Regulation 21 (failure to notify HMRC of a material change).
The largest financial penalty for an AMP in this period was £36,400. This penalty is currently being appealed.

Comparison with previous six-months’ data

The number of penalty notices issued is the same as for the preceding six-month period (335 fines were also issued from 1 October 2024 to 31 March 2025). The total value of the fines is just shy of last year’s figure (at approximately £1.88 million in contrast to £2.25 million previously).

There has been an increase in the number of fines issued against AMPs, rising from 27 to 35 in the latest six-month period.

The smallest fine issued against an AMP of £1,350 is a marginal increase from the fine of £1,250 issued in the previous six-month period.

By contrast, the largest fine of £36,400 was smaller than the largest fine on an AMP – £158,679 – in the prior six-month period.

The Treasury AML Supervision Report – December 2026

The Treasury AML Supervision Report sets out data in relation to HMRC’s assessments / interventions relating to the businesses it supervises (which includes AMPs).

HMRC undertook 451 desk-based reviews and conducted 792 onsite visits in the 2024/25 reporting period.

HMRC reported that of the businesses that received an outcome in the same reporting period in which they were subject to an assessment, 19% were found to be fully compliant, 21% were generally compliant and 60% were non-compliant with the MLRs. As the data demonstrates, not all businesses found to be non-compliant with the MLRs are subject to a fine.

Although the National Risk Assessment in July 2025 downgraded the risk rating of the art market from “high” to “medium risk”, saying:

“HMRC’s improved understanding of the risk in the sector, and therefore our ability to respond to it has driven the decrease in the score. However, there remains a risk of the sector being used for money laundering.”

the AML Supervision Report in December 2025 noted that:

“HMRC identified trust and company service providers, money service businesses and art market participants as the sectors presenting the highest inherent risks for money laundering.” (emphasis added).

The most frequent forms of non-compliance identified in cases closed by HMRC during the 2024/25 reporting period included:

Inadequate documented policies and procedures.
Failure to provide specified information.
Inadequate client risk assessment.
Inadequate record keeping.

Key takeaways

There is a clear “compliance gap” in AML regulation across HMRC’s supervised population

HMRC’s assessment outcomes for 2024/25 shows 60% of businesses were “non-compliant” and only 19% were fully compliant.

Whilst non-compliance does not always result in a fine, greater non-compliance with the MLRs increases the risk that a business could be used to launder criminal funds. Further, fines are more likely for businesses found to be consistently in breach of the MLRs.

AMPs should use the list of common forms of non-compliance to self-assess for potential shortcomings.

Fines and enforcement

Published fines for substantive AML failings (beyond registration issues) have so far been few in the art market.

However, the trends in HMRC’s AML supervisory and enforcement activity generally and the apparent gap in compliance HMRC is finding across the sectors it regulates (it rates a majority of firms (60%) as “non-compliant” in assessments) suggest that tougher action and sanctions are coming.

Notwithstanding that the National Risk Assessment downgraded the art market for AML risk in July 2025, the Treasury AML Supervision Report, and anecdotal evidence of interactions between AMPs and HMRC, suggests that HMRC still considers the AML risks posed by the art market to be significant and requiring of particular attention.

Updating HMRC and the BOOM register

The fine issued to an AMP under Regulation 21 of the MLRs is a reminder of an AMP’s notification obligations:

AMPs must notify HMRC within 30 days of changes within the business including updating its BOOMs register with HMRC.
For a change of MLRO or compliance officer the notification period is 14 days.
It is a criminal offence for a person to act as a beneficial owner, officer or manager of an AMP without approval as such by HMRC (Reg 26(1)).

Questions about the accuracy of the BOOM register have been a consistent theme in AML visits and “interventions” in the past six months.

Should you have any questions on AML regulation or HMRC interventions please contact Roland Foord, Alan Ward, Fran Legg or Anna Purvis.

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