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Essential tips for registering as an Art Market Participant (UK)

Including how to avoid your application being rejected...

In order to carry out activities as an Art Market Participant in the UK, you need to register for supervision with HMRC.

This is an application that needs to be approved - and therefore is possible to have rejected.

Read essential tips immediately below and click through to related resources: How to register; a full guide with downloadable PDF and xlsx; and a step-by-step visual walk-through with screenshots.  

Essential tips for registering:

  • Unless you accept cash payments of 10,000+ EUR (to be changed to 10,000+ GBP in May/June 2026), select only ‘Art Market Participant‘ for regulated sector. (There have been issues with AMP businesses also selecting ‘High Value Dealer’ a.k.a. HVD, which is specifically for accepting cash for 10K+ EUR.)
  • You will be asked about having AML Training as well as your Risk Assessment and AML Policy (incl. policies, controls & procedures) in place. Get in touch with us to find out how we can help you with these – as without them, your application is likely to be stopped.
  • You need to register all BOOMs: Beneficial Owners, Officers (Company Director/s & Secretary) and Manager/s (by title, either employee or contractor). Additionally for your application, these individuals need to have received AML training, whether that’s CPD-certified ArtAML™ training or training delivered internally within your business.
  • When asked about the Fit and Proper Test, the answer as an AMP registrant is “No”. The reason is that there are two ways that regulated businesses qualify for supervision: ‘approval’ OR ‘fit and proper test’. The former applies to AMPs, however confusingly, you will see this option during the registration process – even though it doesn’t apply.
  • It’s paramount that you meet your obligation to have a AML Risk Assessment and Policy (with Policies, Controls and Procedures). Applicants who state ‘no’ to having documented Risk Assessment, Policies, Controls and Procedures can now be rejected after 21 days.
  • HMRC communicates via message in your Government Gateway: When HMRC sends you an email message, you need to log into your AMLS account to read it. If you ever receive a message that looks questionable, you can separately log into your account to see if you have really been contacted. It’s for this reason that they communicate in this manner, instead of sending direct email messages to your inbox.
  • Only one email address can be associated with your AMP registration. Therefore, use an address that will reliably be read in the short as well as long term. Some AMP registrations have lapsed because the team member whose email was associated has gone on extended leave (maternity, illness). 
  • Your AMLS log-in credentials: Keep this in a safe place, ideally encrypted. HMRC has warned that losing the password has caused some registered businesses difficulty in the past.

Important note

The associated Organisation Government Gateway ID is specific to Money Laundering Supervision (and separate to the Government Gateway for Corp Tax, VAT, PAYE, etc).
https://www.gov.uk/guidance/register-or-renew-your-money-laundering-supervision-with-hmrc

Further reading


This article was originally published in 2020, and was last updated in February 2026.