Two thresholds, both now in pounds: what the £10,000 CDD change means for art dealers

As of 30 June, the currency for qualifying transactions under the Money Laundering Regulations has been converted from €10,000 to £10,000. It is a small, sensible change. It is also the right moment to make sure you are not confusing it with the OFSI sanctions reporting threshold we covered in May.

Last month we explained that the threshold for an art market participant’s (AMP) mandatory sanctions reporting to the Office of Financial Sanctions Implementation (OFSI) had been changed from euros into pounds. The other shoe has now dropped. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 have finally also switched to the same currency threshold.  .

So the headline is simple: there is now a consistent threshold for art market participants to  £10,000. The risk is assuming they are the same rule. They are not.

What has actually changed?

Under the Money Laundering Regulations, as of the end of June one is deemed to be an Art Market participant if one by way of business trades, or acts as an intermediary in the sale or purchase of a qualifying work of art, for a value or total purchase price of £10,000 or more In a single transaction, or a series of linked transactions.  The former euro threshold was a hangover from the UK’s membership in the European Union. .  This euro threshold forced art market participants to convert sterling prices into euros to work out whether a sale was in scope.  This was particularly troublesome given currency fluctuations over the last six years. The highest GBP value during the period was approximately £9,420 (when the euro was strongest against sterling, around March 2020 during the early COVID-19 market turmoil, when EUR/GBP briefly traded near 0.9420). The lowest value was approximately £8,260 (when sterling was strongest against the euro, around spring 2022, when EUR/GBP traded near 0.8260)

The 2026 amendment removes that uncertainty by fixing the trigger at £10,000.

Most recently, the €10,000 was worth roughly £8,677 at recent exchange rates, Thus, the move to a round £10,000 has an added benefit of slightly lifting the value of when the UK ML Regulations apply. This is a harmonisation measure, not a tightening of the rules. For most firms the practical effect is simpler arithmetic and cleaner paperwork.

One thresholds, £10,000, two different legal frameworks

The GBP 10,000 figure is relevant to determine if you are conducting relevant transactions and must conduct customer due diligence under the UK ML Regulations. The GBP 10,000 figure also may mandate that an art market participant must report to the Office of Financial Sanctions Implementation actual or attempted breaches of the UK Sanctions law.

The two legal frameworks share a number, but they are separate obligations under separate bodies of law. CDD sits in the Money Laundering Regulations. Sanctions reporting sits in the UK sanctions regime, which has applied to AMPs as “relevant firms” since May 2025. One is about knowing who you are dealing with. The other is about checking that the parties involved are not connected to a sanctioned regime, not designated, and/ or are not controlled by a designated party or more than 50% owned by one a

Two consequences follow. First, clearing CDD does not discharge your sanctions screening, and screening does not discharge your CDD. Second, neither threshold caps your suspicious activity reporting duty. If you suspect money laundering, the obligation to submit a SAR under the Proceeds of Crime Act applies whatever the value of the deal. A sub-£10,000 transaction is never an automatic free pass.

A fresh look at when Enhanced Due Diligence may be required

The same 2026 amendment also recalibrates Enhanced Due Diligence (EDD). High risk jurisdictions may still trigger Enhanced Due Diligence, but what constitutes a high risk jurisdiction has been narrowed. Previously, “high-risk third countries” automatically included the Black and Grey List countries.  Now, automatic EDD is limited to the Black List countries, more formally called the Financial Action Task Force “call for action” countries, currently Iran, North Korea and Myanmar.

In plain terms, for the 22 countries  currently  on the FATF Grey List, art market participants are no longer required  to conduct EDD. It becomes a risk factor to weigh, not a mandatory consequence. The change may be   welcome, but it puts more weight on art market participants’ art judgement, not less.

EDD remains mandatory wherever you identify higher risks, such as politically exposed persons, false or forged documents, and others.  . Where it applies, EDD means establishing the client’s source of wealth from independently verifiable sources and asking the further questions or taking further steps as the circumstances demand.

If you are unsure whether a particular transaction tips into mandatory EDD, that uncertainty is itself a good reason to raise it with your Nominated Officer (your Money Laundering Reporting Officer) before the deal is concluded.

The June 30 Amendment also tweaks the former unusually large or complex risk factor to unusually large or unusually complex. 

What you need to do

A threshold change is a small edit with a wide footprint. The practical steps:

• Refresh your firm-wide risk assessment (regulation 18) to reflect both the new CDD figure and the recalibrated EDD position.
• Update your policies and procedures (regulation 19) so the CDD trigger reads £10,000, not €10,000.
• Amend client-facing documents: terms of business, onboarding forms, invoices and storage agreements.
• Brief your team, so that anyone onboarding clients or pricing works applies the right figure to the right obligation.

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