An anti-money-laundering pack, for a gallery that does not exist.
An art market participant, a dealer, gallery or auction house trading at £10,000 or more, has to assess its own risk, write down its rules and keep records for HMRC. The ArtGuard AML pack writes those documents from the answers to an interview. Below are the seven it writes for Marlowe & Finch Fine Art Ltd, a fictitious London gallery of three people, and the HMRC-visit checklist filled in from the same answers.
Every page of every PDF carries a SAMPLE mark. This sample shows the ratified ArtGuard wording; your own documents are written from your answers.
Every detail about the business is invented: its name, the two people named in it, the HMRC reference number, the address (the postcode ZZ99 9ZZ is invented), the email address and the telephone number (one Ofcom reserves for drama). The regulations, guidance and dates the documents cite are real. The sample was generated on 3 November 2026.
The seven documents
The first two are the documents the Regulations ask a business to have: the risk assessment and the written policies, controls and procedures. The other five are forms, checklists and registers for the business to keep. They are shown as generated, before the business signs them. A document never claims a control the business has not recorded as in place: where one is still to be introduced, the document says so and gives the action.
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Firm-wide risk assessment
The business-wide risk assessment the Regulations require, with its own section for proliferation financing.
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AML policies, controls and procedures
The written policies, controls and procedures: the rules the business follows for customer checks, records, reports and training.
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Internal suspicious-activity report form and register
The form a member of staff uses to report a suspicion to the nominated officer, and the register of those reports.
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Ongoing-monitoring checklist
A checklist for the ongoing monitoring of each customer.
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MLRO review worksheet
A worksheet for the nominated officer’s periodic review of the business’s systems and controls.
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Training register
A register of the anti-money-laundering training the business’s people have had.
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HMRC visit checklist
The ten things HMRC’s guidance says it may ask to see on a visit, with whether the business holds each one and where it is in this pack.
7 PDFs, 1.5 MB in all.
The HMRC-visit checklist
HMRC publishes no annual return for art market participants, so the pack carries a checklist of what its guidance says it may ask to see on a visit: 10 items, each with whether the business holds it and where it is in the pack.