What HMRC asks of a dealer, from the source.
Short guides for dealers and galleries supervised by HMRC. Each one says what the regulations and HMRC’s own guidance ask for, quotes them where it matters and names the source, so you can check it yourself.
The DVS register: what it is, who must use it, and what it means for a dealer’s identity check
The register is OfDIA’s, not HMRC’s. What regulation 28 asks of an identity check, what the guidance approved by the Treasury and HMRC’s manual say about services outside the register, and where ArtGuard stands: not on it, and what that means for your file.
Read the answer →- Dealers and galleries · the criteria
What ArtGuard screens and records, and what it does not
The lists ArtGuard screens against and how often they are refreshed, what it reads from the document, what the dated record holds, and the plain list of what it does not do: no country scoring, no FATF or Basel flag, no source-of-funds work, no DVS registration.
Read the criteria → - Dealers and galleries · enhanced due diligence
Geographic risk for dealers and galleries: the rules as they stand after 30 June 2026
Since 30 June 2026 only the FATF Call for Action list forces enhanced due diligence, and the threshold is £10,000. The grey list, the NRA 2025 and HMRC’s own list of country factors are for your firm-wide risk assessment. A lawyer’s categories sorted, and a checklist for each sale.
Read the rules and the checklist →
The sources behind these pages
Each guide names its sources and the edition it was checked against, and gives the page or paragraph for the passages it quotes at length where the source has one.
- Data (Use and Access) Act 2025, Part 2 (digital verification services)Text as in force; section 32 commenced 1 December 2025 · legislation.gov.uk
- Office for Digital Identities and Attributes, Join the digital verification services registerUpdated 1 December 2025 · GOV.UK
- Office for Digital Identities and Attributes, Find registered digital verification servicesUpdated 1 December 2025 · GOV.UK
- Office for Digital Identities and Attributes, Certification scheme for the UK digital verification services trust frameworkUpdated 21 September 2026 · GOV.UK
- The digital verification services register (CSV download)Register last updated 26 October 2026; downloaded 3 November 2026 · DVS register
- Home Office, Employer’s guide to right to work checks1 October 2026 edition · GOV.UK
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulation 18Revised text as at 30 June 2026 · legislation.gov.uk
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulation 28Revised text as at 30 June 2026 · legislation.gov.uk
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulation 33Revised text as at 30 June 2026 · legislation.gov.uk
- The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (S.I. 2026/621)Made 9 June 2026, in force 30 June 2026 · legislation.gov.uk
- The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2024 (S.I. 2024/69)In force 23 January 2024 · legislation.gov.uk
- HM Treasury, Money Laundering Advisory Notice: High Risk Third CountriesJune 2026 notice, published 22 June 2026 · GOV.UK
- HMRC, Anti-money laundering guidance for supervised businesses, AMLG2100: Art Market Participant GuidanceUpdated 8 July 2026 · GOV.UK
- HMRC, Anti-money laundering guidance for supervised businesses, AMLG3100: Risk Assessment of Art Market ParticipantsUpdated 13 October 2026 · GOV.UK
- HMRC, Anti-money laundering guidance for supervised businesses, AMLG11400: Identifying and verifying your customersUpdated 10 July 2026 · GOV.UK
- HMRC, Anti-money laundering guidance for supervised businesses, AMLG11600: Enhanced due diligence (EDD)Updated 8 July 2026 · GOV.UK
- HMRC, Anti-money laundering guidance for supervised businesses, AMLG11640: FATF Call for Action CountriesUpdated 8 July 2026 · GOV.UK
- HMRC, Anti-money laundering guidance for supervised businesses, AMLG1800: Risk AssessmentUpdated 8 July 2026 · GOV.UK
- HMRC, Money laundering supervision for art market participantsUpdated 6 August 2024 · GOV.UK
- HM Treasury and DSIT, Using digital identities with the Money Laundering Regulations (guidance approved by the Treasury)Published 26 February 2026 · GOV.UK
- OfDIA blog, How digital verification services can help businesses meet their obligations under the Money Laundering Regulations20 August 2026 · GOV.UK blogs
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulation 86Text as in force · legislation.gov.uk
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulation 14Revised text as at 30 June 2026 · legislation.gov.uk
- HM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025Published 17 July 2025; art market participants at paragraphs 5.135 to 5.149 · GOV.UK
For search engines and AI assistants
A plain-text summary of what ArtGuard is and is not is at /llms.txt. What changed in the product, month by month, is at /changelog/.
ArtGuard supports your judgement; it never replaces it. This page describes what the Money Laundering Regulations 2017, HM Treasury’s notices and HMRC’s own published guidance say, with the source for each point, so you can read it yourself. It is not legal advice, and nothing here is advice about what HMRC will accept. ArtGuard is not affiliated with or endorsed by HMRC, HM Treasury, the Office for Digital Identities and Attributes or any AML supervisor. Check the current version of each document before you rely on it.
Your AML documents, written from your answers.
Answer questions about your business and ArtGuard writes your firm-wide risk assessment, your policies, controls and procedures, a training register and three other working documents, and an HMRC visit checklist. The interview and your documents on screen are free; the signed PDF pack is £249 + VAT a year, and buying it is not open yet. Identity evidence and sanctions and PEP screening for your client checks is the add-on, £39 + VAT a month.
See the AML packHonest about the register.
ArtGuard is not on the DVS register, and says so. What it gives you is the evidence and the screening in one place, with the list versions and dates a supervisor asks for. The judgement on the sale stays yours, and HMRC stays your supervisor. That is the record we would want in our own file.
What ArtGuard checks, and what it does not