Who must register

HMRC guidelines

Business sectors supervised by HMRC

  • money service businesses not supervised by the Financial Conduct Authority (FCA)
  • high value dealers handling cash payments for goods totalling 10,000 euros or more on a single transaction or linked transactions
  • trust or company service providers not supervised by the FCA or a professional body
  • accountancy service providers not supervised by a professional body
  • estate agency businesses
  • bill payment service providers not supervised by the FCA
  • telecommunications, digital and IT payment service providers not supervised by the FCA
  • art market participants buying or selling of works of art where the transaction value (or a series of linked transactions) is 10,000 euros or more
  • letting agency businesses renting property or land valued at the equivalent of 10,000 euros or more a month

You need to register with HMRC if you carry out activities typically associated with these types of organisations by way of business and you are not already registered.

Estate Agents

Businesses that must register:

  • high street residential estate agencies
  • commercial estate agencies
  • online estate agencies
  • property or land auctioneers
  • land agents
  • relocation agents, property finders, private acquisitions specialists
  • a sub-agent providing estate agency services to a main estate agency business
  • asset management businesses that also provide estate agency services
  • business brokers or transfer agents brokering the sales or transfer of client businesses to third parties
  • social housing associations that offer estate agency services
  • letting or property management agents that offer estate agency services to landlord customers
  • construction companies (residential property builders) with a sales office on- site, where they act or offer additional estate agency services other than the sale of their own construction properties
  • a solicitor's property centre in Scotland

More information about estate agency businesses regulations available here

Art market participants

Who should register.

An art market participant under the money laundering regulations is a company or sole practitioner who is either:

  • 'by way of business' trading in, or acts as an intermediary in, the buying or selling of works of art where the transaction value (or a series of linked transactions) is 10,000 euros or more
  • the operator of a Freeport storing works of art in the Freeport and the value for a person (or a series of linked persons) is 10,000 euros or more

Intermediaries

An intermediary is someone who, by way of business, is actively involved in the sale or purchase of a work of art, on behalf of a seller or buyer. This involves dealing with more than one party. The intermediary will have authority to act on behalf of a seller or buyer.

You should register as an art market participant if you:

  • negotiate the price of the art piece with another art market participant
  • act on behalf of a customer during a sale or purchase

More information about art market regulations available here


This information is based on content from HM Revenue & Customs (HMRC) and is used under the terms of the Open Government Licence v3.0

The original content can be found on the GOV.UK website.