How do galleries run AML checks without slowing the sale?

Galleries run AML checks without slowing the sale by taking the administration out of the compliance officer's hands and leaving the judgement in them. The identity documents and the information the gallery's own process asks for are requested the day a sale is agreed, chased on a schedule, checked for completeness, filed in the gallery's own document store and linked from the collector's record. The compliance officer sees a complete file, decides, and the decision is recorded.

Updated

How do the checks run alongside the sale?

We build it around the software your gallery already runs; for galleries and art advisers that is Artlogic. Artlogic's support centre says its database records whether a check was obtained, who carried it out and when, and that the documents themselves, such as copies of passports, need an external system linked from the record: that is where the system files them. The system does the administrative work around the checks: collecting, chasing, filing and recording. What the checks are, and whether a file satisfies them, is your compliance officer's decision, and every step below is a rule your firm sets rather than a black box. This page rests on HMRC's guidance for the United Kingdom, read on 25 October 2026; rules elsewhere differ, and your compliance officer says which apply to you.

  1. Decide the process first, and write it down

    In the United Kingdom, HMRC says it is the default anti-money laundering supervisor for art market participants. Its guidance on registering says a company or sole practitioner must register with HMRC if, by way of business, it 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 euros or more. HMRC's manual, published 8 July 2026 and last updated 13 October 2026, says on its page for the sector that the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 changed that threshold to 10,000 pounds, and that its sector-specific guidance is awaiting ministerial sign-off, and that in the meantime art market participants must follow Part 1 of the manual, the guidance for all sectors, and Part 3, the sector risk assessments, along with the British Art Market Federation's guidance. HMRC's risk assessment for the sector says every art market participant must carry out a written risk assessment and put policies, controls and procedures in place to manage the risks it finds. Whether your gallery is within those rules, and what its process is, is a question for your compliance officer, not for us. The system runs the process the officer writes down.

  2. Open the file the moment a sale is agreed

    HMRC's guidance says customer due diligence means taking steps to identify your customers and checking they are who they say they are, and its manual says the checks cover the customer and, where applicable, the beneficial owners, anyone acting on the customer's behalf, and the purpose and intended nature of the relationship or transaction. For an individual, the manual says the business should obtain, as a minimum, the full name, date of birth and residential address, and must then verify them with identity evidence or electronic verification. When a sale is agreed in your system, the request for whatever your officer's checklist asks for goes out in the gallery's voice that day, not when someone is back from the fair.

  3. Chase on a schedule that does not forget on fair week

    Missing documents are chased on a sequence the gallery sets, and the sequence runs on fair week as it does in August. HMRC's manual says that if a business cannot verify a customer's identity it must not proceed with the transaction or establish the business relationship, so a request that goes unanswered is flagged to the compliance officer with the dates, rather than left to lapse in an inbox.

  4. Check the file for completeness, not for truth

    The system checks that every item on the officer's list is present, legible and in date, and lays the file out against that list. It does not decide whether a document is genuine or a risk acceptable. HMRC's manual says a business should do more than obtain the documents: it should check each one, among other things the spelling, the expiry date and that the photograph is the customer's. That is the officer's work, and the system puts the document and the checklist in front of them. The manual also says identity can be verified through a digital verification service certified against the UK trust framework and on the DVS register; whether your gallery uses one is the officer's choice, and the system records the result either way. For online and remote sales, HMRC's risk assessment for the sector recommends a video call to check the person is genuine and is the person in the documents; the system books the call, and the officer holds it.

  5. Put the complete file in front of the compliance officer, who decides

    HMRC's manual says a customer's identity, and where applicable a beneficial owner's, must be verified before a business relationship is established or a transaction carried out where due diligence is required. It describes one very limited exception, for a business relationship only, under which, it says, verification must still be completed as soon as practicable after contact is first established. The decision on a file is a person's. The gallery can set the rule that the invoice does not complete until the officer's decision is recorded; the system holds that step, and nothing else.

  6. Record the decision, and keep the file

    HMRC's manual says a business must keep copies of the documents and information obtained for due diligence, and enough supporting records to reconstruct the transaction, for five years after the business relationship ends or the transaction completes, and must then delete the personal data unless one of the exceptions it lists applies. The system files the documents in the gallery's own document store, linked from the collector's record, records the decision and its date against the collector and the sale, logs every access, keeps sensitive data apart, and flags the dates the officer sets for review and deletion. No client is named without consent.

  7. Measure days from agreed sale to completed checks

    You see, for every sale, when it was agreed, when the request went out, when the file was complete and when the officer decided. Days from agreed sale to completed checks is the number the review measures first. Once that journey holds, the same system takes on the provenance and condition files, the follow-up after a fair or a viewing, and the coordination of a private sale.

What does this replace?

The email and spreadsheet status quo

After

What is a slow check costing the gallery?

The first cost is the sale that cools. A collector who agrees a price at a fair and then hears nothing for a week while documents are gathered is a collector with time to change their mind, and the compliance officer's hours go into chasing rather than deciding. Compliance shouldn't be what slows the sale. The second cost is the file nobody can find: HMRC's manual says the records of the checks must be kept for five years after the relationship ends or the transaction completes, so a check that was done but not filed is paid for twice, once in the doing and once in the looking. Neither cost appears on a report today. The review measures both on your own sales, days from agreed sale to completed checks first, before anything is built.

How long does it take to set up?

It starts with a review, about a week, that finds where requests and documents stall and what each fix is worth. A first working version is usually live in two to four weeks: one journey, the file from agreed sale to recorded decision, live in your systems against a written baseline. Provenance and condition files, fair follow-up and private-sale coordination follow once that holds through real sales.

When is this not worth doing?

Frequently asked questions

How do galleries run AML checks without slowing the sale?

By having the administration around the checks run on its own and leaving the judgement with the compliance officer. The request for documents goes out the day a sale is agreed, missing items are chased on a schedule, the file is checked for completeness and put in front of the officer, and the decision is recorded against the collector and the sale. It runs inside the software the gallery already uses, so nothing is replaced.

Which galleries have to run AML checks?

In the United Kingdom, HMRC's guidance says a company or sole practitioner must register with HMRC as an art market participant if, by way of business, it trades in or acts as an intermediary in the buying or selling of works of art where a transaction, or a series of linked transactions, is 10,000 euros or more, and HMRC's manual page for the sector says the 2026 amendment regulations changed that threshold to 10,000 pounds. The same guidance says there is no need to register for someone who only gives art advice, charges a fee for research or provenance checks without being involved in the sale or purchase, introduces customers to an art market participant who then carries out the transaction, or provides non-regulated services such as framing, shipping or art installation, nor for an artist who sells their own work directly to customers, as an individual or through a business they own, and does not sell art created by other people. Whether your firm is within those rules is a question for your compliance officer.

What does HMRC say customer due diligence is?

HMRC's guidance says customer due diligence means taking steps to identify your customers and checking they are who they say they are: in practice a name, a photograph on an official document, a residential address and a date of birth. Its manual adds, where applicable, identifying and verifying beneficial owners and anyone acting on the customer's behalf, understanding the ownership and control of a company or trust, obtaining information on the purpose and intended nature of the relationship or transaction, ongoing monitoring, and keeping records. The manual says the checks apply when a business relationship is established and for an occasional transaction over the sector's threshold, which it prints as 10,000 pounds for art market participants, reached in one operation or in linked ones: its example is two paintings bought for 5,000 pounds each on the same day from the same participant.

Can a sale complete before the checks are finished?

HMRC's manual says a customer's identity, and where applicable a beneficial owner's, must be verified before a business relationship is established or a transaction carried out where due diligence is required. It describes one exception, for a business relationship only, where beginning to set it up before verification is necessary so as not to interrupt the normal conduct of business and there is little risk of money laundering or terrorist financing; even then, it says, verification must still be completed as soon as practicable after contact is first established, and a business using the exception is expected to keep a written record of why it considers the relationship presents little risk. It also says that a business that cannot complete the checks must not proceed with the transaction or the relationship. When any of that applies to a sale is your compliance officer's call, and the system records the call.

Does the system decide whether a collector passes?

No: every action sits behind one of three gates. Confirmations, reminders and filing run on their own. Requests to a collector are drafted in the gallery's voice and wait for a person to approve them. The decision on a file, like anything sensitive and anything leaving the firm, is a person's, and the system records who made it and when.

How much does it cost to set this up?

It starts with a review, about a week, that measures how long your checks take today and says what each fix is worth. The build is then scoped and quoted at a fixed price, against acceptance criteria written before it begins. After that we run and extend it monthly, and you can cancel at any time.

Sources

Every statement on this page about a named company, a price or a rule was read at its source on 25 October 2026. Prices and policies change: read them again before you rely on them.

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