- February 6, 2025
- Posted by: FCS Compliance
- Category: Art Market, News
As we look ahead to 2025, there are several important developments on the horizon for art market participants (AMPs) that will shape compliance efforts, regulatory obligations, and industry trends. From mandatory changes in financial sanctions reporting to the anticipated revisions in the UK’s National Risk Assessment, these updates will require AMPs to adapt their compliance programmes and stay ahead of evolving regulations. Below are the key developments expected in the coming months and years.
Key Developments to Watch in 2025
1. Adapting to OFSI’s New Guidance
The biggest news for AMPs is the need to adapt their compliance programmes in line with new advice and mandatory requirements from the Office of Financial Sanctions Implementation (OFSI), set to take effect in May 2025. AMPs will need to ensure their internal processes are ready for these changes. We are hosting a free webinar on 7 March at 12pm (GMT), with sanctions specialist, Alexandra Melia, partner at Steptoe, to hear how this change affects AMPs and to ask any questions you may have.
2. Change to the Euro 10,000 Threshold in the 5th EU ML Directive
We also anticipate changes to the threshold figure for compliance under the 5th EU Money Laundering (ML) Directive. The current €10,000 figure will likely be revised to a GBP amount, with estimates predicting the new threshold will range between £8,000 and £10,000. This may trigger compliance for more transactions and parties in the art market.
3. Updated Guidance from Her Majesty’s Treasury (HMT)
We expect an update to the UK’s guidance for Art Market Participants (AMPs), hopefully by the end of this year. Knowledge of this guidance will be essential in ensuring AMPs comply with the most current regulatory expectations.
4. The 2025 UK National Risk Assessment
Following the 2020 National Risk Assessment (NRA), which identified the art market as being at high risk for money laundering, the UK Government is expected to release a new assessment possibly by year end 2025. There is speculation on whether the art market will remain classified as a high-risk sector, or if it will be downgraded to medium or low risk. The results of this report will have significant implications for the level of scrutiny AMPs face moving forward.
5. Continued Acceleration of HMRC Penalties
We expect the acceleration of HMRC penalties for non-compliance to continue into 2025. Rumours suggest that penalties may be extended to poor implementation of the UK Money Laundering Regulations (MLR), rather than solely focusing on lapses or failures in registration. AMPs should be aware of this potential shift in enforcement priorities.
Highlights for 2025
The calendar for 2025 is already filling up with key events and opportunities for engagement:
- The Art Business Conference, Maastricht, The Netherlands – March 2025
- TEFAF, Maastricht, The Netherlands – March 2025
Speaking Engagements
Rena Neville, from FCS, is invited to speak at several prestigious events, including:
- Harvard Art Law Organization, Boston – 26 March 2025, where she will discuss the latest trends in art market regulations and AML compliance.
- American Bar Association (ABA) webinar, Rena is currently scheduled to participate in “Preserving Culture, Preventing Crime: Insights on Art and Antiquities AML Compliance,” scheduled for March 12, 2025, from 8:00 AM to 10:00 AM EST.
Upcoming FCS Webinars
FCS will continue offering valuable webinars throughout 2025, addressing critical issues in AML compliance for AMPs. Notable webinars include:
- Stricter Sanctions Reporting Obligations: 7 March 2025 As of May 2025, art market participants will be designated as “Relevant Firms” by OFSI. This free webinar (find out more here) will explore the practical implications of this change and how it affects the art market.
- Coming soon – In Conversation with the NCA: Discussing how AMPs can avoid penalties by ensuring proper filing of suspicious activity reports. – Save the date, 7 April 2025
Conclusion
The art market is entering a period of significant regulatory change in 2025, and it is essential for AMPs to stay informed and prepared. From adapting compliance programmes in line with OFSI’s updated guidelines to anticipating changes in the UK National Risk Assessment, the next year will bring both challenges and opportunities for art market participants. FCS is committed to providing ongoing support through expert insights, webinars, and speaking engagements to ensure AMPs navigate these changes effectively and remain compliant with evolving AML and sanctions regulations.
