Your gallery’s AML documents, written from your answers.
Answer questions about your business. ArtGuard writes your risk assessment, your policies, controls and procedures, four working documents and an HMRC visit checklist. Start free, with no card: the interview and your documents on screen cost nothing. The signed PDF pack is £249 + VAT a year, and buying it is not open yet.
Questions about your business. Not a blank page.
Eight groups of questions: your business and its people, your customers, the works and services you deal in, the countries involved, how you deal with people, how you are paid, the controls you have or still need, and the documents you already hold. Most questions are answered by choosing an option. Nothing is asked twice. Your progress is saved, so you can stop and come back.
Already have a risk assessment, policies or a training log? Upload them. ArtGuard reads each once and shows what it supports as suggestions, which you confirm or reject one by one. Nothing becomes an answer without your confirmation. Upload your customer list and it is counted by code, not read by a model; the file and the counts are kept, and no row is copied into your answers.
Seven documents from your answers
Your risk assessment
Your customers, the countries you are connected with, the works and services, how you are paid and how you deal with people, with the controls and actions and its own proliferation-financing section.
Your policies, controls and procedures
How you check a customer, when you look harder and what triggers it, how you keep watch, what you keep on file, who your nominated officer is, how your people are trained, and who approves it.
Your HMRC visit checklist
The ten things HMRC’s guidance says it may ask to see on a visit, each marked held, to introduce, not held yet or not applicable from your answers, with where it is in your pack or your own records.
Four working documents
A form and register for reporting a suspicion inside the business, an ongoing-monitoring checklist for each customer, your nominated officer’s review worksheet, and a training register.
Missing controls stay visible
If a control is not in place, the document says so and gives the action. It never claims you do something you do not do. If you have not yet screened your customers, it says so instead of printing a zero.
Every rule names its source
Every statement of the law is fixed wording chosen by your answers, and names the regulation or the HMRC guidance behind it. Your own answers are printed as you gave them. Customer numbers appear as the bands you chose, never a name.
See the finished example for a fictitious gallery: the seven PDFs and the visit checklist →
Review, sign, keep current
“HMRC expects a risk assessment to be more than a ‘tick box’ approach. You must be able to provide an up-to-date copy of your risk assessment, and the information you have used to carry out that risk assessment to HMRC upon request.”
HMRC, Risk assessment of art market participants (AMLG3100), updated 13 October 2026
Source: AMLG3100 on GOV.UK.
Who it is for
Dealers, galleries, auction houses and advisers who buy, sell or broker works of art at £10,000 or more, in one transaction or a linked series, and who are registered with HMRC for anti-money-laundering supervision. The Money Laundering Regulations call that business an art market participant, and HMRC asks it to declare a written risk assessment and written policies, controls and procedures when it registers. Selling work created by, or attributable to, someone in your own firm does not count.
The pack stands on its own. You do not need ArtGuard Verify, the buyer check (£39 + VAT a month, separate), and you do not need to have run a single check with us. Your own answers produce complete documents.
What it costs
The signed PDF pack, bought on its own. No Verify subscription needed.
- The interview and your documents on screen: free, no card; create your account and open AML pack from the menu
- Your risk assessment, with its proliferation-financing section
- Your policies, controls and procedures
- Four working documents and the HMRC visit checklist
- Your risk assessment and policies dated, with their review due date
Prices exclude VAT. Buying the PDF pack is not open yet. Until it is, the interview and on-screen documents are free. Email hello@artguard.uk to be told when buying opens.
Your judgement still matters
ArtGuard supports your judgement; it does not replace it. The decisions in your risk assessment and your policies, and whether a case is suspicious, remain yours and your nominated officer’s.
Having the pack does not mean your business meets its AML obligations. ArtGuard is not a regulator and is not affiliated with or endorsed by HMRC. Nothing on this page is advice about what HMRC will accept.
Start free, or look first.
Create your account, open AML pack from the menu and answer the first group of questions, or read the finished example for a fictitious gallery first.
Start your pack, free See a finished exampleNo card · the signed PDF pack is £249 + VAT a year, not yet on sale · hello@artguard.uk