- February 20, 2026
- Posted by: Rena Neville
- Category: Art Market
Anti-money laundering regulation in the art market continues to develop, with 2025 bringing greater regulatory clarity and increased supervisory focus. As Art Market Participants prepare for further change in 2026, understanding current requirements and emerging expectations is essential.
In the Art Market AML Update: Your 2026 Need-To-Know Guide webinar, I examined recent developments and outlined what compliance teams should be prioritising as the regulatory landscape evolves.
This article summarises the key insights from the webinar and highlights the practical considerations for art businesses navigating AML obligations.
Webinar overview
The webinar explored how AML regulation is shaping the art market, with a focus on:
- Updated HMRC guidance for Art Market Participants from September 2025
- Key themes from the recent UK government AML consultation
- Enforcement activity and sanctions obligations on Art Market Participants
- Recommendations resulting from the UK National Risk Assessment
- US and EU Money Laundering regulatory developments in the art market
- Anticipated AML developments in 2026
The session provided practical context to help businesses understand how regulatory expectations apply in real-world art market scenarios.
Key takeaways for Art Market Participants
Updated HMRC guidance
HMRC has issued updated guidance clarifying how Art Market Participants should identify, assess and manage money laundering, terrorist financing and proliferation financing risks.
A central requirement is the need for a written annual risk assessment that reflects the specific nature of an art business and, most importantly, responds to the risks highlighted for the market by the Regulator. The most recent HMRC Guidance focused on customer, transaction, channel and jurisdiction risks. Mitigation steps may be proportionate and evidence-based.
The guidance reinforces the expectation that AML frameworks are tailored to the Art Market Participant’s individual business profile, rather than adapted from generic financial services models.
Government AML consultation
The most recent government consultation highlighted areas where further regulatory clarity is expected. HM Treasury recommends that HMRC provide clarification to Art Market Participants on points such as: business relationships, expectations around source of funds checks for high-value transactions, and the growing role of digital identity verification in customer due diligence. We expect to see guidance on these topics, as well as a change to applying a GBP threshold to qualifying transactions from the current Euro threshold.
National Risk Assessment update
The latest UK National Risk Assessment has reclassified the art market from high risk to medium risk for money laundering.
While this reflects progress in regulatory oversight and sector understanding, it does not appear to have led to a reduction in scrutiny. Regulators continue to focus on weaknesses such as inadequate risk assessments, poorly implemented policies and failures to submit Suspicious Activity Reports where required.
Perhaps indicating which way the wind is blowing, the 2025 NRAR acknowledged that there are risks involving works of art in addition to those specifically included in the scope of the current UK ML Regulatory definition of work of art, which is based on the 1994 VAT Act, as amended.
Strong documentation and effective implementation remain essential.
International regulatory developments
The webinar also addressed regulatory change beyond the UK. The Art Market Integrity Act was proposed in the United States Senate in Summer 2025. The priority of the proposed bill is to extend AML obligations beyond antiquities to a broader definition of work of art. It is anyone’s guess if or when the bill will become law.
In contrast, the EU has taken decisive action, and it set a deadline for July 2027 to add luxury goods, such as jewellery and antique automobiles, within its AML framework.
What to expect in the UK in 2026
New UK Money Laundering Regulations
Revised UK Money Laundering Regulations are expected to come into force in 2026. The most relevant change we predict is converting the Euro 10,000 work of art value threshold that currently triggers UK ML Regulatory compliance to a GBP 10,000 figure. This will end the need to convert local pound transactions into Euros to assess whether customer due diligence is required.
Increased supervisory activity
Further guidance from HMRC and HM Treasury is anticipated, alongside increased inspection activity. Regulators are expected to focus not only on written policies, but on how AML controls operate in practice.
Penalties for non-compliance
Regulators have signalled continued enforcement focus, with the potential for increased penalties where serious or repeated compliance failures are identified. Maintaining up-to-date policies, training records, and audit trails will be critical.
Don’t commit an “own goal”, please register if you must and remember to keep your AMP HMRC registrations fully accurate and up to date. Otherwise, we expect to continue to see fines in these areas.
Conclusion
The regulatory environment for the art market continues to evolve and seems to us to be more closely supervised. Art Market Participants should ensure their AML frameworks are risk-based, proportionate and aligned with current guidance.
The Art Market AML Update webinar underscored the importance of proactive compliance planning, effective documentation and ongoing review. Businesses that take early action will be better positioned to meet regulatory expectations and reduce enforcement risk in the year ahead.
Next steps
If you would like to assess how prepared your business is for the upcoming AML changes, FCS Compliance can support Art Market Participants with risk assessments, policy reviews and ongoing compliance advice tailored to the art sector.
Staying informed and taking early action will be key to navigating regulatory change with confidence.
Contact us to see how we can help.
About the Author
Rena Neville
Head of FCS Compliance Art Division
Rena is a qualified lawyer and art market AML specialist. She enjoyed a 30-year career at Sotheby’s becoming their first Global Compliance Director, having previously served as their European General Counsel and Global Head of Litigation. She benefits from a unique combination of art world and international legal experience. Leading the FCS Compliance Art Division, Rena assists many Art Market Practitioners providing them with the practical information and tools they need to ensure they and their firms are meeting the legal AML compliance obligations.
