10,000 Changes Everything Campaign | British Institute of Interior Design

Clone of Clone of 10,000 Changes Everything

The BIID has launched a campaign to help interior designers understand how anti-money laundering regulations may affect their work.

Sourcing art for clients can bring you within UK anti-money laundering law.

Spends of £10,000 or more — including linked purchases — may require checks on your client and the transaction.

If you are not registered with HMRC and compliant, you risk fines, loss of banking services, and even prosecution. Are you exposed?

Clone of 10,000 Changes Everything

The BIID has launched a campaign to help interior designers understand how anti-money laundering regulations may affect their work.

Sourcing art for clients can bring you within UK anti-money laundering law.

Spends of £10,000 or more — including linked purchases — may require checks on your client and the transaction.

If you are not registered with HMRC and compliant, you risk fines, loss of banking services, and even prosecution. Are you exposed?

Helpline

Discover when the £10,000 threshold applies—and what your practice may need to do

In order to provide expert assistance on this complex topic, the BIID has launched a helpline for Anti Money Laundering compliance advice exclusively for its professional members. Read here for more information, this can also be found in the Member Area.

This is to go alongside the existing legal, CDM and HR helplines we offer members.

Example Scenarios

Discover when the £10,000 threshold applies—and what your practice may need to do

We have created some example scenarios of when designers may have obligations under the Money Laundering Regulations (2017):

Scenario 1 – The Family Home

An interior design practice is commissioned to complete a turnkey renovation of a Wiltshire house. As part of the furnishing stage of the project and in line with their retail model of charging they select six original paintings from different galleries across the UK. Their design studio purchases the paintings, then they supply then directly to the client and invoice the client including their handling fee. Although none of the individual purchases exceeds the legal threshold of £10,000, together they do, and as they form part of the same interior design project they could be treated as linked transactions. As the designer has no experience with anti money laundering (AML) compliance they are not aware that it is their responsibility to check if they fall under the regulations.

Scenario 2 – The City Apartment

A client asks their interior designer to help them source artwork for a London apartment. The designer identifies suitable pieces, negotiates prices with several galleries and asks each gallery to invoice the client directly, while the designer charges a separate fee for the sourcing service. The designer is aware that Money Laundering Regulations apply to the art market but because their practice did not purchase the artwork directly they assume that the regulations do not apply to them.

Scenario 3 – The Boutique Hotel Refurbishment

An interior design practice is appointed to refurbish a small boutique hotel, including sourcing original artwork for the reception, restaurant and guest rooms. The practice agrees all artwork selections with the client, places the orders with multiple galleries on the hotel's behalf and oversees the delivery and installation of every piece, charging a procurement fee for managing the process. The team focuses on delivering the project on time and on budget, without realising that their involvement in arranging the artwork transactions may mean the business has responsibilities under the Money Laundering Regulations.

What qualifies as a work of art?

Discover when the £10,000 threshold applies—and what your practice may need to do

This guide is intended to help interior designers understand the types of objects that may fall within the UK's anti-money laundering regulations. It is not a legal definition, but a practical guide. If you are unsure whether a particular item is a 'work of art' for the purposes of the regulations, you should seek professional advice.

These are generally considered works of art

Original paintings
Original drawings and illustrations
Sculptures and statuary
Original prints, engravings and lithographs (including signed or limited editions where appropriate)
Limited-edition artistic photographs
Artist-created mixed media works
Artist-made tapestries and textile artworks
Artist-made ceramics sold as artworks
Artist-made glass artworks
Installation and conceptual artworks

These are generally not considered works of art

Furniture
Lighting
Soft furnishings
Mirrors
Rugs and carpets
Home accessories and decorative objects produced as functional products
Most antiques that are not works of art (for example antique furniture or clocks)

Items that may depend on the circumstances

Some objects sit in a grey area. Whether they are considered works of art can depend on how they are created, marketed and sold.

Ceramics
Glass
Contemporary craft
Designer objects
Decorative objects
Textiles

The Campaign

The campaign

Discover when the £10,000 threshold applies—and what your practice may need to do

When many people think about anti-money laundering laws, they think of banks, solicitors or accountants rather than the design and creative sectors.

However UK anti-money laundering regulations also cover anyone who by way of business negotiates sales or purchases of paintings, certain prints, certain photographs, sculpture and other works. parts of the art market. That means interior designers who source, purchase or are involved in transactions to purchase artwork for clients may have legal responsibilities they are completely unaware of. The BIID has previously published articles and run webinars on this topic but our conversations with designers have revealed that many are still unaware of the importance of this issue – and that is why we have launched the £10,000 Changes Everything campaign.

The aim of the campaign is simple: to help interior designers understand when these rules may apply, what their responsibilities are, and where to go for further guidance.

Interior design and sourcing art

Many interior designers source paintings, sculpture, photography and other original works of art as part of their work for clients. In many cases the designer isn't intermediary “recommending pieces, liaising with galleries, arranging purchases or advising and assisting acting their client. It's precisely these activities that can bring a business within the scope of the UK's anti-money laundering regulations. If you or your business are undertaking these activities you may be considered an ‘Art Market Participant’ and be required to register with HMRC.

The £10,000 threshold

The regulations generally apply to designers where a transaction involving works of art is worth £10,000 or more. However, this doesn't necessarily mean one artwork worth £10,000. The law covers a single or “series of linked transactions” which in simple terms means a number of separate art purchases that are connected because they form part of the same client project or the same overall arrangement. Splitting a purchase into more than one invoice, or allowing instalments payments of less than £10,000 do not avoid the regulations. For example, if you source several original artworks for the same client, those purchases may be treated as one transaction if they are linked. Simply splitting a purchase into smaller orders does not necessarily take it outside the regulations.

Works of Art that require compliance

Not all works of art are within the scope of the ML Regulations. Typically books, furniture etc are not included. What is included? Very generally, works of art includes: all paintings, drawings, collages, decorative plaques or similar picture, and all original sculpture or statuary. It also includes the following categories but each category is subject to a different qualifying limitation (edition number, requiring a signature, etc) original engraving, lithograph or print, sculpture casts, tapestry or other hangings, ceramics, enamel on copper or photographs. It is important to explore the specific object types, characteristics, limited edition, and signature rules for each category.
Becoming compliant (if required)

If you or your practice is an art market participant in transactions over the £10,000 threshold the following actions may be required:

Registering with HM Revenue & Customs (HMRC) for anti-money laundering supervision (where required)
Creating required documents such as a Business Risk Assessment and Policy
Attending annual training
Carrying out customer due diligence
Identifying and verifying clients and, where appropriate, beneficial owners
Assessing money laundering risk
Keeping records
Reporting suspicious activity where legally required

Why this matters for designers and design practices

HM Revenue & Customs has already taken enforcement action against many businesses in the art market for failing to comply with the regulations. This has included financial penalties for failing to register or meet other compliance requirements. The purpose of this campaign is not to alarm designers. It is to ensure that no practice is caught unaware. Understanding your legal responsibilities is simply part of running a professional business.
The BIID has launched an Art Market Participant helpline [link to helpline page], available exclusively to BIID members, to help provide support and guidance.

Could these rules apply to you?

Please review What qualifies as a work of art? to understand what items fall under the regulations
Please review the checklist we have created to see if these rules may apply to you and your practice

Understanding whether these rules apply to your business can help you continue sourcing artwork for clients with confidence.