Ahead of the upcoming fair season, if you are looking to conduct sales in the United Kingdom you must have a written Risk Assessment Policy. The Risk Assessment Policy includes a written analysis of the current potential of your particular business being targeted for money laundering. You must also have a policy in place that establishes controls and procedures on how to train staff and lessen the likelihood for money laundering by conducting customer due diligence at a level appropriate for your business generally and each individual transaction.
The HMRC has indicated that they may be conducting compliance checks at upcoming fairs or via written communications with participating art market professionals that fall under the regulations. Such professionals include but are not limited to gallerist, dealers, auction houses, advisors, and other intermediaries involved with negotiating a sale.
Currently, all art market professionals will have to register with the HMRC to receive a VAT number as a non-established-taxable-persons (NETPs) in order to access the art market progressional registration.