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UK art market rules and this product

UK art market participants supervised under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("MLR 2017") need policies, CDD, risk-based decisions, and records. HMRC is the main supervisor for many in-scope galleries and dealers. The table below is a plain-English map to where Proofenance supports your process. It is not legal or regulatory advice. Your MLRO, policy, and professional advisers remain definitive.

Proofenance is not a substitute for an MLRO, a written risk assessment, or your own customer due diligence policy. It is a way to run and evidence checks against each sale so your registers and the ProofMark Report tell one story.

Mapping (high level)

MLR 2017 theme (simplified)What you still ownWhat Proofenance helps you do in practice
Risk assessment and internal controlsGallery or dealer methodology, governance, and approval of risk appetiteSales run in a consistent workspace, training hooks exist, and the ProofMark Report shows what you did for that sale
CDD: identify and verifyProportionate steps for your client and risk, document retentionIdentity and verification flows tied to the purchase, with evidence stored for the file
Source of funds and wealth (when required)Policy on when to ask, and how to judge answersBank and statement workflows attached to the sale, so SoF is not a detached email
EDD where risk demands itWhat additional steps your policy requires, and when to declineDiligence questionnaires, uploads, and decisions with reasons, all on the same sale record
Ongoing monitoring and record keepingObligations to refresh and retainAudit and export material aligned to the purchase; investigations tooling in the platform

HMRC registration

Galleries and dealers in scope need to be on the appropriate registers and meet HMRC expectations. Proofenance includes onboarding and guidance in the company and compliance experience so you can work through art market participant context as you set up, without losing the link to the sales you will run later in the purchase workspace. Your registration and obligations remain yours to complete and evidence outside any software brand.

Further reading on this site

Last updated: April 2026. Regulations and guidance change; we refresh this page when we materially update the product or public content.