Sample · HMRC-visit checklist
The HMRC-visit checklist, filled in.
HMRC publishes no return for art market participants, so the pack carries a checklist of the things its guidance says it may ask to see on a visit. Each row says whether the business’s answers show it holds the item, and where it is in the pack. Marlowe & Finch Fine Art Ltd is a fictitious gallery.
10 items, as at 3 November 2026
The items below are those HMRC’s guidance says it may ask for, inspect or require. This is a preparation list, not a statement that the business holds them.
10 items: 8 held, 1 to introduce, 1 not applicable, 0 not held yet.
| # | What HMRC may ask for | Status | Where it is |
|---|---|---|---|
| 1 | The current firm-wide risk assessment, with the information it was based on and the record of the steps taken to prepare it (reg 18(6); HMRC AMLG1800). | Held | Firm-wide risk assessment (this pack) |
| 2 | Previous versions of the risk assessment, kept for at least five years (HMRC AMLG1800). | Held | Firm-wide risk assessment (this pack) |
| 3 | The recorded reasons for any decision that a case was not high risk despite a risk factor (HMRC AMLG1800). | Held | Firm-wide risk assessment (this pack) |
| 4 | The proliferation financing risk assessment, with the information it was based on (reg 18A(5)). | Held | Firm-wide risk assessment (this pack) |
| 5 | The written policies, controls and procedures (HMRC AMLG1900). | Held | AML policies, controls and procedures (this pack) |
| 6 | The training record: who was trained, when, the content and format, and any assessment of its effectiveness (HMRC AMLG11030). | Held | Training register (this pack) |
| 7 | Copies of the SARs the business has submitted (HMRC AMLG11100). | Not applicable No reports made in the past two years, so there are no copies to show. | Internal suspicious-activity report form and register (this pack) |
| 8 | The record of potential suspicious activity, the assessment of it and the reasons a SAR was or was not submitted (HMRC AMLG11100). | Held | Internal suspicious-activity report form and register (this pack) |
| 9 | Customer due diligence and transaction records, kept as evidence for any HMRC investigation and, where held outside the UK, readily available when HMRC requires them, with a certified translation of any document in a language the business’s staff do not understand (HMRC AMLG11700; HMRC AMLG11400). | Held | The business’s own records |
| 10 | For any case where enhanced due diligence was required but a source of funds or source of wealth measure was not taken, the evidence-based explanation of why (HMRC AMLG11630). | To introduce | The business’s own records |
The regulations and HMRC guidance named in each row are real; the business and everyone named in this pack are invented. The checklist is a preparation list, not a statement that a real business holds anything.