Her Majesty’s Revenue & Customs in the UK issued guidance to help the art market understand the AML risks it faces and how to best address them. One of many points of interest: Before one regulated Art Market Participant (AMP-1) transacts with a fellow Art Market Participant (AMP-2), AMP-1 should check the HMRC Register to see if AMP-2 is registered, and if not, HMRC suggests AMP-1 should not proceed with the transaction and should consider filing a Suspicious Activity Report. Here is the link: ‘Understanding Risks and Taking Action for art market participant businesses’
On April 14th, 2021, the Society of Fine Art Auctioneers and Valuers hosted Corinth Consulting, represented by Rena Neville and Paula Trommel, along with SoFAA Committee member and art law consultant Tom Christopherson. The live Q&A session, dedicated exclusively to SoFAA members, was entitled “AML and HMRC: Are you Really Prepared?” and focused on the practical meaning and application of the UK AML regime.
The Art Basel UBS 2021 Art Market Report features an article by Rena Neville entitled: The Anti-Money Laundering Difference: Knowing the Ultimate Customer. The article addresses the initial impact on the art market of the EU’s 5th Money Laundering Directive, particularly in the UK. Find it on pages 44-47, https://www.artbasel.com/about/initiatives/the-art-market
In the article, Rena Neville and Paula Trommel explore the trend of increased art market AML regulation in the UK and US, with each country having a different focus. The varying international approaches may be due to the lack of hard data underpinning the regulations. Regardless, global inconsistency adds to the complexity of compliance.
November 5, 2021