A message from CEO and co-founder, Susan J. Mumford:
As 2026 finds its stride, I want to outline key regulatory changes expected for the regulated art market.
It’s already shaping up to be a busy yet productive year, with some settling of what AML compliance means for the UK art market and, for our US readers, growing momentum on the regulatory front there too. It’s worth noting that the EU market will follow suit in 2027 with the introduction of both 6AMLD and the Anti-Money Laundering Regulation (AMLR) — more on those soon. While some changes require adjustment, they should ultimately bring additional clarity and trust to how the market operates. Getting clear on these early will make compliance more manageable.
We’ll keep you updated as the regulatory landscape develops. If you have questions or want to talk through what this means for your business, get in touch.
All best, as always,
Susan
Strategic approach to sanctions enforcement – UK
The new policy paper sets out how sanctions will be enforced across government and what businesses can expect when compliance falls short. For Art Market Participants, key points are that sanctions obligations apply independently of AML thresholds, civil breaches are assessed on a strict liability basis and having documented screening controls in place can work in your favour if enforcement action is ever taken against you. An AMP’s inability to evidence screening doesn’t in itself constitute a breach but it leaves an AMP entirely exposed if a breach is alleged.
Anti-Money Laundering Authority (AMLA) – EU
AMLA took over all EU AML/CFT responsibilities from the European Banking Authority (EBA) on 1st January. By 10th July 2026, it must publish a substantial package of technical standards and guidelines, including risk assessment methodologies for non-financial obliged entities like AMPs. These will define compliance expectations when the AML Regulation enters into force on 10 July 2027th. We’re closely monitoring these standards and will update clients as the requirements for AMPs become clear.
HMRC Guidance to replace BAMF Guidance – UK
The British Art Market Federation (BAMF) Guidance on Anti-Money Laundering (AML) for UK AMPs is expected to be replaced by new statutory guidance issued by HMRC. Once approved by HM Treasury, this guidance will carry formal recognition in a court of law, providing clarity and legal certainty for the sector’s compliance efforts. Further detail will be shared as this guidance is finalised.
Customer Due Diligence Threshold update – UK
The UK government is changing the anti-money laundering (AML) Customer Due Diligence (CDD) threshold for AMPs from €10,000 to £10,000, with the change expected to take effect in late Spring. This update is intended to streamline compliance, reduce administrative effort and better reflect how the UK art market operates in practice. It will also simplify calculations for obligations such as the Artist’s Resale Right.
FATF Lists to replace domestic High Risk Third Countries List – UK
Another significant change anticipated in late spring is the adoption of the Financial Action Task Force (FATF) black and grey country lists, set to replace the UK-specific High Risk Third Countries list. Art businesses should also factor in HMRC’s Risk Assessment for the art market (September 2025) and the National Risk Assessment (July 2025) when evaluating customer risk.
Companies House Identity Verification – UK
November will mark the close of the 12-month transition period for Companies House’s identity verification requirements. These reforms, introduced under the Economic Crime and Corporate Transparency Act, aim to enhance the trustworthiness of the register by verifying that the individuals behind companies are who they claim to be. AMPs should ensure relevant individuals have completed verification ahead of the deadline.
AML compliance proposed for the American art market – US
Introduced in July 2025, the bipartisan Art Market Integrity Act (AMIA) (S. 2400) proposes to bring US art dealers, galleries, auction houses and advisors within the scope of the Bank Secrecy Act (BSA) anti-money laundering (AML) requirements. If enacted, it would close a long-standing regulatory gap between the US and the EU and UK. While the bill has bipartisan backing, it has prompted concern within the art market. Insiders say that the current bill won’t pass, but only time will tell. We will continue to monitor AMIA’s progress through Congress, sharing updates as and when they become available.