In an update to the money laundering supervision guidance, HMRC has clarified that intermediaries who are actively involved in the sale or purchase of a work of art, on behalf of a seller or buyer, must sign up as an art market participant if they negotiate the price of a painting or art piece with another art market participant, such as an art gallery, auction house or online platform.

They will also be caught by the registration rules if they act on behalf of a customer during a sale or purchase as an agent, for example.

This follows the release of updated guidance on the anti-money laundering (AML) rules for art market participants by HMRC.