What ArtGuard screens and records, and what it does not

1. What is read from the buyer

HMRC’s guidance sets the minimum you collect for a private individual.

As a minimum, you should obtain all of the following details for a private individual:

• Full name.
• Date of birth; and,
• Residential address.

ArtGuard collects these on the buyer’s own phone, through a link you send. The buyer photographs a passport or other identity document. The machine-readable zone is read and its check digits tested, which gives the full name as the issuing state printed it, the date of birth, the nationality, the document number and the expiry date. Where a read is partial the buyer is asked again; a partial read is never confirmed. The buyer then takes a live selfie, which is matched to the photograph on the document, and photographs an address document such as a driving licence, bank statement or utility bill, from which the address is read. An address counts as verified only when the name on that document matches the identity being checked.

On an iPhone the buyer can also hold the passport to the phone and read its chip. The record shows when a chip read was made. The result is reported by the phone, and ArtGuard does not yet verify the chip’s digital signature on its own servers, so a chip read is presented to your officer for review rather than treated as a verified chip. The matching engine used for the face comparison is named on each record.

HMRC lists what it wants verified: “The customer’s full name, photograph, date of birth and residential address must be verified by ID evidence.” The ArtGuard record carries all four, with the images, so your officer can do that verification against the document and, where your risk assessment calls for it, add the steps HMRC recommends for remote sales (an original seen in person, or a video call).

2. What the name is screened against

Three things about the screening are worth knowing. First, every fetch of every sanctions list is logged, whether the list changed or not, so a list that silently stops updating is visible. Second, a freshness gate: if a list is stale at the time of a check, the result is escalated to review, never shown as clear. Third, the record names the version of each list and the date it was fetched, so a check can be replayed against the same lists later. A doubtful match is flagged for your officer rather than resolved by the software. Since 15 September 2026 the PEP roster has carried no country filter, because relatives and close associates are listed for who they are related to, not for an office they hold, and most carry no country of their own.

HM Treasury’s notice of 22 June 2026 points out that several of the countries on the FATF lists are also under UK financial sanctions, which is why the sanctions screen matters to country risk even though ArtGuard holds no country list: “Of these jurisdictions, the following are also subject to financial sanctions measures at the time of publication of this notice, which require firms to take additional measures”. A designated person from any of them will show on the UK Sanctions List screen. On whether screening must come from a registered service, OfDIA’s note of 20 August 2026 says: “There is no obligation to source attributes from certified and registered DVS but it is strongly recommended.”

3. After the check

Regulation 28(11) asks for ongoing monitoring of a business relationship, including “undertaking reviews of existing records and keeping the documents or information obtained for the purpose of applying customer due diligence measures up-to-date”. For a returning collector you can set ArtGuard to re-screen the details already held every month, quarter or year. Each run is logged whether or not anything changed, and if a run finds a worse result than the last you are emailed. Re-screening is the sanctions and PEP part of monitoring, not the whole of it: the scrutiny of the transaction itself stays with you.

4. What the record contains

Each check produces a dated evidence file for your account. It carries the buyer’s name, date of birth, nationality and address as read; the document type and images; how the identity was read (from the document on the server, posted by the browser, or a chip read reported by the phone); the face-match result and the engine that produced it; the sanctions, PEP and disqualified-officer results with the list versions and fetch dates; any item flagged for review and what your officer did with it; and a SHA-256 hash of the file’s contents, so a copy can be shown unaltered later. The record does not contain a risk rating for the buyer’s country, a recommendation on enhanced due diligence or a verdict on the sale, because those are not ArtGuard’s to give.

5. What ArtGuard does not do

This is the part a compliance adviser most needs. The table maps the country-risk categories an adviser will typically send to what ArtGuard gives you and what remains yours.

Two more lines belong here. ArtGuard is not on the digital verification services register and holds no certificate against the UK digital verification services trust framework. The HM Treasury and DSIT guidance of 26 February 2026, approved by the Treasury for the purposes of the Regulations, says services outside the register “cannot reliably be deemed suitable for identity verification in compliance with the MLRs”, so an ArtGuard check is not something a dealer should rely on as their regulation 28 verification: it is a dated record of the document, the photograph match and the screening that sits alongside your own verification or a registered provider’s check. The DVS register page explains this in full. And ArtGuard is not your supervisor or your adviser: registering with HMRC, the firm-wide risk assessment, the policies and the decision on each sale remain yours. HMRC puts the point about third-party providers plainly.

Care must be undertaken when using third parties, as any breach of the regulations may result in sanctions, including financial penalties or criminal charges, on you or your business, as the supervised entity: use of a third party does not absolve you of your responsibility for compliance.

6. Where the geographic facts sit on the record

For the client-by-client checklist, the record answers the factual questions and leaves the judgement ones to you.

Questions people ask

Sources

The product facts on this page are from ArtGuard’s own code and documentation as deployed on the day this page was last checked. The quotations are from:

• HMRC, Anti-money laundering guidance for supervised businesses, AMLG3100: Risk Assessment of Art Market ParticipantsUpdated 15 October 2026 · GOV.UK
• HMRC, Anti-money laundering guidance for supervised businesses, AMLG11400: Identifying and verifying your customersUpdated 10 July 2026 · 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
• HM Treasury, Money Laundering Advisory Notice: High Risk Third CountriesJune 2026 notice, published 22 June 2026 · 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

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.