Who can set up AML onboarding for a gallery or art adviser?

Four kinds of provider set up AML onboarding for a gallery or art adviser. Your gallery software's vendor trains you on its due diligence features. An AML service built for the art market verifies identity and screens collectors. A compliance adviser writes the policy. An independent builder, such as Alea Applied AI, runs the collecting, chasing and filing across your tools and stays to operate it. Your own team can do it too. Your compliance officer decides each file.

Updated 25 October 2026

Who does this work, and when does each one fit?

The first four are providers; the fifth is doing it yourself. They overlap, and each starts from a different part of onboarding. What each company says is from its own pages, read on 25 October 2026, and the prices are in pounds, as the pages print them. The rules are paraphrased from HMRC's guidance for the United Kingdom: whether your firm is within them, and what its process is, is your compliance officer's decision, not ours.

The gallery software vendor's own team
Artlogic's onboarding page says its team designs an onboarding plan around the size and complexity of the business, the Artlogic products bought and the software being moved from, and helps organise the data through import templates, step by step help guides or bespoke data analysis; it says its onboarding team, based in the UK and the US, includes many people with direct experience of working in galleries. Its support centre describes customer due diligence tools in the database: on each contact, whether a check was obtained, who carried it out, when, and a warning when it expires, which it does automatically after a year; on each invoice, a status of approved, failed, required or not required. The same article says the database cannot store the due diligence documents, such as copies of passports, and is too open a forum for risk assessment scores, so clients need an external system for both, with a field for the link. Its training page prices one-to-one sessions at 200 pounds an hour plus VAT, with bundles of three, four and five hours at 400, 500 and 600 pounds, and its support centre says every client has email support and Artlogic Pro accounts have phone support. On 25 October 2026 its pricing page listed the gallery platform from 156 pounds a month for Essential and from 311 for Professional with its yearly option selected, or 169 and 342 with its quarterly option, and the Expert plan, with a dedicated account manager, on request. Artlogic also lists freelance specialists in its products, who it says are not employed by it; none of the listings on that page mentions anti-money laundering. This route fits when the due diligence fields are already in the software you pay for and nobody is using them.
An AML service built for the art market
Arcarta describes itself as the due diligence network for the art market. Its page for galleries says a gallery sends a collector a secure link and Arcarta's forms guide the collector through the process, that collectors who have been through due diligence with Arcarta before can consent to share it, and that its API and webhooks support integrations with a gallery's CRM and database; it has a page for advisers too. Its getting-started page is an enquiry form and prints no price, and its training page lists online AML courses for the UK and the EU at 99.99 pounds for one person and 169.99 for two. ArtAML describes itself as the complete anti-money laundering solution for the art world. On 25 October 2026 its pricing page listed, excluding tax, due diligence plans from 55 pounds a month for Lite CDD, with one user and up to twelve verifications a year, to 153 pounds a month for Advanced CDD, on monthly billing, and bundles that add its training and a risk assessment and policy from 95 to 191 pounds a month, paid monthly on a one-year subscription; a due diligence plan can be tried free for ten days. The same page lists screening for politically exposed persons and sanctions, identity verification with liveness and face match checks, and a secure upload link for collectors. This route fits when the gap is the checks themselves: verifying who the collector is, screening them and keeping the evidence.
A compliance adviser, or the trade body's guidance
HMRC's risk assessment for the sector says every art market participant must carry out a risk assessment of its own, keep an up-to-date written record of the steps it took, and put in place policies, controls and procedures to manage the risks it finds. A compliance adviser helps a gallery decide what that process is and write it down. The British Art Market Federation publishes Guidance on Anti Money Laundering for UK Art Market Participants: its page lists the 2023 guidelines, amended and approved by HM Treasury on 6 February 2023, and the guidance says it is merely guidance and not intended as a substitute for legal advice. HMRC's anti-money laundering manual, published 8 July 2026 and last updated 13 October 2026, says on its page for the sector that HMRC's own sector guidance is awaiting ministerial sign-off, that until then art market participants must follow Part 1 and Part 3 of HMRC's guidance, the guidance for all sectors and the sector risk assessments, along with the Federation's, and that the Federation's guidance does not reflect changes made by the Money Laundering and Terrorist Financing (Amendment) Regulations 2026, among them the change of the threshold from 10,000 euros to 10,000 pounds. Some of the services in the second step do part of this work: ArtAML's bundles include a risk assessment and policy prepared from a questionnaire. This route fits when nobody has yet decided what the gallery's process is, or when the rules have changed since it was written.
An independent builder
An independent builder does the administrative work around the checks, across the tools the gallery already runs, and stays to operate it. That is our work. For galleries and art advisers we run collector onboarding and AML checks, provenance and condition files, fair and viewing follow-up and private-sale coordination, inside the software you already use, such as Artlogic. The request for documents goes out the day a sale is agreed, missing items are chased on a schedule, and the file is checked for completeness; the documents are filed in the gallery's own document store and linked from the collector's record. Every action sits behind one of three gates: confirmations, reminders and filing run on their own; requests to a collector are drafted and wait for a person to approve them; and a person decides payments, anything sensitive and anything leaving the firm, the decision on each file among them. Every access is logged, sensitive data is kept apart, and no client is named without consent. Anything the rules do not cover goes to a named person with the context already gathered. The number we measure first is days from agreed sale to completed checks. This route fits when the checks are in hand but the collecting, chasing and filing around them slow the sale, or when that work falls between the inbox, the gallery system and the due diligence service.
Your own team
Artlogic's support centre says the due diligence features are set in the database's preferences, where those for contacts are on by default and an administrator switches on those for invoices; that every administrator can see the due diligence information; and that access for other users is granted user by user. Its support centre has guides and video tutorials, and its training page lists free webinars each month. If the gallery makes only a few sales that need the checks and someone has the hours, the fields you already pay for, a written checklist and a diligent compliance officer are the place to start. It stops fitting when the officer is also the person selling at the fair.

What do we do, and on what terms?

We build and run the system inside the software your gallery already uses. It starts with a review, about a week, that finds where requests and documents stall and what each fix is worth. The build is then scoped and quoted at a fixed price, and a first working version is usually live in two to four weeks: one client journey, live in your systems, against a written baseline. The acceptance criteria are written before any build begins: what the system will do, measured how, by when. If it misses, the fix is ours. After that we run and extend it, monthly, and you can cancel at any time.

What should you ask before you sign with anyone?

What will the system do, measured how, by when? Get that on paper before the work starts: it is what you will hold the provider to. The number we measure first is days from agreed sale to completed checks.
Who decides on each file, and is that written down? HMRC's guidance on your responsibilities says a business's controls should include appointing a nominated officer, and a compliance officer if the business is larger or more complex. Ask every provider which steps its system takes on its own and which it leaves to that person.
If a provider keeps the records, who answers for them? HMRC's manual says a business that delegates its record keeping to a third party remains responsible for its record keeping obligations, and must make sure the third party keeps the records accordingly. It says the identification evidence and the records needed to reconstruct a transaction must be kept for five years after the business relationship ends or the transaction completes, and that the personal data must then be deleted unless an exception applies. Ask each provider how it keeps and deletes them.
Where are the documents and records held, and who can open them? HMRC's manual says that where records are held outside the UK, the UK business must make sure they meet UK requirements and are readily available when HMRC asks for them. Ask each provider where it keeps them, who can see them, and whether every access is logged.
If a provider offers due diligence that another business has already carried out, ask your compliance officer whether and how to rely on it. HMRC's manual says a business that relies on a third party remains responsible for any failure to apply due diligence measures appropriately, and should consider reliance a risk in itself.
Can a sale complete before the checks are done? HMRC's manual says a business that cannot verify a customer's identity must not proceed with the transaction or establish the business relationship. Ask how the system holds a sale until the officer's decision is recorded.
Who owns the workflows and the data if you part ways?

When are we the wrong choice?

If the gallery software you pay for already has the due diligence fields your officer needs and nobody is using them, that is a setup and training job for the vendor's own team, not a build
If the only gap is verifying identity and screening collectors, an AML service built for the art market is the direct answer
If what you need is someone to decide what your process should be, that is a compliance adviser's work, not ours: we run the process your officer writes down
If you make only a handful of sales a year that need the checks, a checklist and a diligent officer are fine, and we will say so
If you are about to change your gallery software, wait until that settles rather than building twice

Frequently asked questions

Who can set up AML onboarding for a gallery or art adviser?

The vendor of your gallery software, an AML service built for the art market, a compliance adviser working with the trade body's guidance, an independent builder, or your own team. The vendor trains you on the software you bought, and an AML service verifies identity and screens collectors. An independent builder does the collecting, chasing and filing around the checks inside the tools you already run, and operates it afterwards. Whoever does the work, the decision on each file stays with your compliance officer.

What does Artlogic include for customer due diligence?

Artlogic's support centre describes due diligence tools in its database: on each contact, whether a check was obtained, who carried it out, when, and a warning when it expires after a year; on each invoice, a status of approved, failed, required or not required. The same article says the database cannot store the due diligence documents, such as copies of passports, and is too open a forum for risk assessment scores, so clients need an external system for both, with a field for the link. The features are set in the database's preferences, where those for contacts are on by default and an administrator switches on those for invoices.

What do AML services for the art market cost?

On 25 October 2026 ArtAML's pricing page listed, excluding tax, due diligence plans from 55 pounds a month on monthly billing, for one user and up to twelve verifications a year, and bundles with training and a risk assessment and policy from 95 pounds a month, paid monthly on a one-year subscription. Arcarta's getting-started page is an enquiry form and prints no price; its training page lists its online AML course at 99.99 pounds for one person. Artlogic's training page prices one-to-one sessions at 200 pounds an hour plus VAT. Ours starts with a review, about a week, and the build is then quoted at a fixed price.

Does an art adviser have to register with HMRC?

HMRC's guidance on registering says a company or sole practitioner that, by way of business, trades in or acts as an intermediary in the buying or selling of works of art, where the transaction or a series of linked transactions is 10,000 euros or more, has to register, and that an intermediary should register if it negotiates the price with another art market participant or acts on a customer's behalf during a sale or purchase. It 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, or introduces customers to an art market participant who then carries out the transaction. HMRC's manual page for the sector says the 2026 amendment regulations changed the threshold to 10,000 pounds. Which side of that line your firm is on is a question for your compliance adviser, not for us.

Who decides whether a collector passes the checks?

A person, not a system. HMRC's guidance on your responsibilities says a business's controls should include appointing a nominated officer, and a compliance officer if the business is larger or more complex. In what we build, confirmations, reminders and filing run on their own, requests to a collector are drafted and wait for a person to approve them, and the decision on each file is your compliance officer's, recorded with who made it and when.

What is the British Art Market Federation's guidance?

The Federation publishes Guidance on Anti Money Laundering for UK Art Market Participants: its page lists the 2023 guidelines, amended and approved by HM Treasury on 6 February 2023, and the guidance says it is merely guidance and not intended as a substitute for legal advice. HMRC's anti-money laundering manual, published 8 July 2026 and last updated 13 October 2026, says on its page for the sector that art market participants must follow the Federation's guidance, with Part 1 and Part 3 of HMRC's own guidance, until HMRC's sector guidance is signed off, that the Federation's guidance does not reflect changes made by the 2026 amendment regulations, and that where those changes apply and the two differ, HMRC's Part 1 is the one to follow. HMRC says the Federation's guidance will cease to be in effect once its own is published.

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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Who can set up AML onboarding for a gallery or art adviser?

Who does this work, and when does each one fit?

The gallery software vendor's own team

An AML service built for the art market

A compliance adviser, or the trade body's guidance

An independent builder

Your own team

What do we do, and on what terms?

What should you ask before you sign with anyone?

When are we the wrong choice?

Frequently asked questions

Who can set up AML onboarding for a gallery or art adviser?

What does Artlogic include for customer due diligence?

What do AML services for the art market cost?

Does an art adviser have to register with HMRC?

Who decides whether a collector passes the checks?

What is the British Art Market Federation's guidance?

Sources

See where the time is going