On 7 February, HMRC published information to help one find out if you’re an art market participant and need to register with HMRC under the Money Laundering Regulations.  This follows implementation of the 5th EU AML Directive.  Those subject to control includes the operator of a freeport where the participant stores works of art in a freeport where the value for a person (or a series of linked persons) is €10,000 or more.  A freeport is a warehouse or storage facility within an area chosen by HM Treasury as a special area for customs purpose.  On the same day, HMRC also issued guidance on how to help prevent money laundering and terrorist financing for art market participants.  It includes information on customer due diligence (CDD), record-keeping and reporting suspicious activity.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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