A U.S. bill that would introduce AML compliance to the American art market

August 6, 2025

There’s potentially a big development across the pond:

The recently introduced bipartisan ‘Art Market Integrity Act’ (AMIA), brought forward by Senators Chuck Grassley and John Fetterman, could bring U.S. art businesses under the anti-money laundering and counter-terrorism financing (AML/CTF) regulations of the Bank Secrecy Act.

Concerns

While this might seem like a sensible development that is in harmony with existing AML legislation in the EU and UK, there are concerns about:

Inconsistency with previous recommendations by the U.S. Treasury; and
Money and motivations behind the bill.

How the U.S. Treasury Report (2022) compares

The U.S. Treasury report (2022) cited an example of applying AML/CTF measures to institutions (Art Market Participants) with annual sales near the range of $500,000 – $1 million. The newly proposed bill diverges from this approach, broadly applying the AMIA to legal persons (art dealers, galleries, auction houses, art consultants, custodians, museums, collectors and others) unless any of the following apply:

During the prior year, they didn’t participate in a single transaction valued over $10,000 that involved a work of art;
They have not, during the prior year, participated in total transactions valued at $50,000 that involved a work of art; or
They are engaged in the art market for the sole purpose of selling works of art created by themselves.

There is a wide divergence between relevant businesses in the Treasury report vs. newly proposed U.S. bill.

Moreover, while the Treasury report moots the idea of reporting requirements being triggered by individual transactions of $50,000 for a single transaction or aggregate yearly transactions of $200,000 by a single buyer, the 2025 U.S. bill does not provide any reporting specifications. Does this indicate that measures would need to be applied to all transactions for regulated businesses, or might this be outlined in Guidance?

This is a significant distinction and needs clarity as the majority of art transactions are ‘occasional’ and not ongoing ‘business relationships’, with triggering thresholds such as those in the UK and EU a keystone to legislation.

Lobbying and interests behind the bill

A key voice behind the bill is the Antiquities Coalition. Public messaging by this anti-trade body emphasises that the illicit antiquities trade is a multi-billion dollar criminal industry financing extremists and erasing cultural heritage. Despite a striking lack of evidence for these claims – as debunked in a Rand Report from 2020, Cultural Property News has stated in response to the AMIA that:

“…the Antiquities Coalition has pursued this mission through high-profile partnerships, advocacy campaigns and policy initiatives that have dramatically influenced the discourse and laws on cultural property over the past decade.”

It is our understanding that they receive funding from the U.S. State Department and have strong links to a for-profit international consultancy business with deep ties to the Middle East and the People’s Republic of China. Conflicts of interest are rife.

It is prudent that the Antiquities Coalition discloses lobbying and interests per the Lobbying Disclosure Act of 1995. The point of the Act is to ensure transparency and allow the public to evaluate potential undue influence on government decision-making – which is presently a concern of ours as a pro-market AML provider to the international art market.

In Conclusion

The introduction of the Art Market Integrity Act represents a pivotal moment for the U.S. art market, signalling a potential shift toward comprehensive AML/CTF regulation that would bring it closer in line with frameworks already in place across the UK and EU. However, the proposed scope of the legislation raises critical questions, not only about its alignment with the U.S. Treasury’s own recommendations, but also about the motivations and interests driving its development.

As an AML compliance provider committed to fostering a transparent, secure and compliant international art market, we welcome thoughtful regulation that is proportional, risk-based, and informed by a nuanced understanding of the industry. That said, sweeping legislative measures influenced by lobbying interests – without clear thresholds or guidance, risk undermining the very goals they purport to achieve.

We strongly urge policymakers to engage with art market professionals, compliance specialists, and legal experts to ensure any new regulations are effective, practical, and rooted in evidence. The future of the U.S. art market’s integrity depends not just on regulation—but on getting it right.