A message from CEO and co-founder Susan J. Mumford:
As 2025 draws to a close, I wanted to reflect on what has been a pivotal year for the regulated art market.
From the UK’s explicit inclusion of Art Market Participants in Sanctions Law to the launch of the EU’s Anti-Money Laundering Authority and HMRC’s newly published Risk Assessment, the compliance landscape has continued to evolve at pace. Regulators have moved from guidance to enforcement, raising expectations for demonstrable compliance and robust documentation.
Alongside actively supporting the sector with AML compliance—for example, authoring the Portugal section of the Center for Art Law’s 2nd edition of the comparative AML study—we stepped up our commitment to a sustainable sector by becoming an active member of the Gallery Climate Coalition (GCC). This is timely too, as the number of events we attend has increased, making our commitment to sustainable transportation all the more important.
Looking to 2026, the regulatory environment will continue to demand attention and adaptation. We’re committed to staying ahead of developments and keeping you informed. Thank you for your continued trust—and watch this space as we continue streamlining compliance through evolving technology.
Continue reading to discover updates from the past year.
–Susan J. Mumford
CEO + co-founder, ArtAML™
ArtAML™ achieves Gallery Climate Coalition (GCC) Active Membership
In May, we became an Active Member of the Gallery Climate Coalition (GCC). This recognises the environmentally responsible best practices we have put in place in line with GCC guidance and reflects our ongoing commitment to sustainability and responsible operations in providing a service to the art market.
Sanctions compliance for UK Art Market Participants and High Value Dealers
As of 14th May 2025, Art Market Participants (AMPs) and High Value Dealers (HVDs) based in the UK are explicitly named under UK Sanctions Law and must comply with requirements or face potential penalties. The Office of Financial Sanctions Implementation (OFSI) published guidance to help AMPs and HVDs understand what this means in practice. 2025 has seen tougher sanctions enforcement across the market, with greater transparency around penalties, prosecutions and disclosure notices.
EU Anti-Money Laundering Authority (AMLA)
On 1st July 2025, the EU’s Anti-Money Laundering Authority (AMLA) officially launched operations in Frankfurt, marking a fundamental shift toward centralized, harmonized AML/CFT supervision across member states. While AMLA won’t directly supervise art market participants, it will coordinate with national supervisors to ensure consistent application of AML rules EU-wide and will set compliance benchmarks through its direct supervision of 40 high-risk financial institutions beginning in 2028. National supervisors remain the primary regulators for AMPs, but AMLA’s establishment signals an era of more rigorous, harmonized oversight across the EU.
HMRC’s Risk Assessment for AMPs replaces 2021 Risk Guidance
This new Risk Assessment published in September 2025 not only replaces previous Risk Guidance, it signifies a shift from advisory to regulatory expectation. Issued under Regulations 17 and 47 of the Money Laundering Regulations, it requires AMPs to incorporate it into their business-wide risk assessments.
The document cites the National Risk Assessment (published July 2025) downgrade of the sector’s money laundering risk from ‘high’ to ‘medium’ while highlighting emerging threats including crypto-asset payments, art price manipulation and intermediary sales.
A major addition is proliferation financing, requiring AMPs to screen clients against the UK Sanctions List, particularly for Iran, North Korea, Russia and Syria. Risk assessments, policies and procedures must be written, regularly reviewed and provided to HMRC upon request. What was once best practice is now demonstrable regulatory compliance.
The Center for Art Law’s comparative AML study, 2nd edition
The Center for Art Law published the second edition of its ‘Anti-Money Laundering Regulations and the Art Market Study.’ Released in October, it offers a substantially expanded global perspective on how anti-money laundering regulations impact Art Market Participants, now covering 12 additional jurisdictions with thoroughly updated analysis throughout. We’re proud to have contributed to this resource, with our CEO and co-founder, Susan J. Mumford, authoring the section on Portugal.
Sign up for our newsletter to receive our 2026 Outlook — coming soon.