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 forStatusWhere it is
1The 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).HeldFirm-wide risk assessment (this pack)
2Previous versions of the risk assessment, kept for at least five years (HMRC AMLG1800).HeldFirm-wide risk assessment (this pack)
3The recorded reasons for any decision that a case was not high risk despite a risk factor (HMRC AMLG1800).HeldFirm-wide risk assessment (this pack)
4The proliferation financing risk assessment, with the information it was based on (reg 18A(5)).HeldFirm-wide risk assessment (this pack)
5The written policies, controls and procedures (HMRC AMLG1900).HeldAML policies, controls and procedures (this pack)
6The training record: who was trained, when, the content and format, and any assessment of its effectiveness (HMRC AMLG11030).HeldTraining register (this pack)
7Copies 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)
8The record of potential suspicious activity, the assessment of it and the reasons a SAR was or was not submitted (HMRC AMLG11100).HeldInternal suspicious-activity report form and register (this pack)
9Customer 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).HeldThe business’s own records
10For 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 introduceThe 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.

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