HMRC Proposes AML Fee Increases for AMPs

HMRC Proposes AML Fee Increases for Art Market Participants — Consultation Open Until 29 August

HM Revenue & Customs (HMRC) has announced proposed changes to the fees it charges for anti-money laundering (AML) supervision —  raising the cost of compliance for UK Art Market Participants (AMPs).

Key Proposed AML Supervision Fee Changes (2025)

Under the new proposals — currently under consultation until 29 August 2025 — several AML supervision fees may increase:

  • Premises fee: rising from £300 to £400 per location (annual fee)
  • Application fee: a one-off £400 charge
  • Sanctions administration charge: increasing the penalty administration charge to a sanctions charge of up to £2,000
  • Approvals fee: unchanged at £40 per person

According to HMRC, the changes are intended to ensure that the costs of AML supervision are covered by supervised businesses rather than the taxpayer. While these proposals do not necessarily signal greater enforcement activity, they do represent a shift towards full cost recovery.

Rena Neville, Head of the Art Division at FCS Compliance, notes:

“We strongly encourage all AMPs to respond to the government’s consultation and share their views. If you’re a member of a trade association, let them know too. HMRC has fined hundreds of AMPs in recent years – often for avoidable oversights like missed registrations. This consultation is an opportunity for the art market to engage constructively with the process.”

Fines on the Rise: A Reminder of the Importance of Registration

Alongside the consultation, HMRC has reiterated the importance of maintaining accurate registration. In the most recently posted penalties by HMRC, 79 AMPs were fined a combined total of over £550,000, with the vast majority of penalties issued for failures to register or renew on time.

These figures underscore how vital it is to stay on top of AML obligations. 

Avoid Penalties with AML Protect

As compliance deadlines approach, FCS Compliance recommends that AMPs take steps to prevent accidental lapses in registration — one of the most common causes of enforcement action.

AML Protect is a free, secure reminder tool that helps regulated businesses avoid missing critical dates, such as MLR registration renewals. Open to all HMRC-supervised firms — regardless of whether or not you are an FCS clients — thise tool enables users to:

  • Create a free account
  • Set a personalised renewal reminders
  • Receive automated alerts before their MLR registration expires

It’s a simple, effective way to stay compliant and avoid preventable fines.

Set your AML reminder today