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.