Anti-money laundering for art galleries: what applies, and where

A gallery in Paris sells a painting to a collector in New York, ships it from a warehouse in Geneva and exhibits the next month at a fair in London. Four countries, four sets of anti-money laundering rules for art galleries, and one question every gallerist ends up asking: what do I actually have to do?

This guide maps the ground for art galleries in the UK, the EU and the US: what each regime asks, what they all ask, and what none of them asks. The differences are smaller than they look.

It is not legal advice and does not replace a lawyer’s view of your own situation.

In the UK, anti-money laundering starts with a register

Under the Money Laundering Regulations 2017, an art market participant is a business that trades in works of art, or acts as an intermediary in their sale or purchase, where a transaction or a series of linked transactions is worth 10,000 euros or more.

The obligation with no equivalent elsewhere: you must register with HMRC before carrying on business where a transaction of that size is likely.

HMRC began issuing fines in April 2022. Of the 408 businesses penalised in 2023 for breaches of the regulations, ten were art galleries, and published fines have ranged from £1,250 to £52,000. Trading while unregistered is a criminal offence carrying up to two years’ imprisonment, for the company, its senior managers and the staff involved alike.

Three points often missed:

• A gallery based abroad that comes to sell at a London fair, and expects a sale above the threshold, is in scope and must register. Being established elsewhere is no exemption.

• An artist selling their own work is outside the scope. The gallery representing them is not.

• The trigger is changing currency: after an eighteen-month consultation, HM Treasury indicated in July 2025 that the threshold should be redenominated in pounds sterling, and HMRC updated its guidance for art market participants in October 2025.

In the EU, one anti-money laundering threshold and many national versions

The Fifth Anti-Money Laundering Directive brought art dealers into scope across the EU, from 10,000 euros per transaction or series of linked transactions, whatever the means of payment. What each country did with it varies.

• France transposed the directive in February 2020 and names galleries in its monetary and financial code. The supervisor is the customs administration, which announced in June 2026 that risk assessments and internal procedures would be checked systematically during inspections. Records are kept for five years.

• Italy brought galleries and auction houses into its 2007 decree in 2019. Suspicious transaction reports go to the Financial Intelligence Unit at the Bank of Italy. Records are kept for ten years, and knowingly holding false client data carries six months to three years in prison.

• Spain is the outlier: professional dealers in art and antiques are obliged entities with no transaction threshold at all. The person designated to liaise with the financial intelligence unit must also have received documented external training.

Cash ceilings are a separate matter, unrelated to the 10,000 euro due diligence threshold. Spain and France cap cash payments at 1,000 euros and Italy at 5,000 euros, while Germany, Austria and Ireland set no limit.

One date to have in mind: Regulation (EU) 2024/1624 applies directly in all twenty-seven member states from 10 July 2027, with no national transposition. It harmonises customer due diligence, lowers the beneficial ownership threshold to 15% and caps cash payments at 10,000 euros across the Union. The UK is not covered, so a gallery selling into both markets will still be running two frameworks after 2027.

In the US, no rule for art dealers, but real exposure

There is no federal anti-money laundering regime for art dealers in the United States. The Anti-Money Laundering Act of 2020 extended Bank Secrecy Act obligations to dealers in antiquities and ordered a study of the wider art market. The study was published. No final rule for art dealers has followed.

An American gallery is not without exposure, though. Sanctions compliance applies regardless, and handling the proceeds of crime is an offence with or without a sector rule. A US gallery selling to a European buyer, or exhibiting in London, steps into someone else’s rules.

In practice, your American counterparty may have no compliance file, no client identification process and no idea why you are asking. That is not a red flag. It is a reason to explain why you ask.

The four habits that hold everywhere

Four habits survive in every regime.

1. Identify before you sell, not when you invoice. Every framework places verification before the transaction. It is the requirement most often missed.

2. Know who is actually buying. When a company buys, the natural person controlling it must be identified. From July 2027, the EU threshold for that drops from 25% to 15%.

3. Watch the accumulation, not the invoice. Linked transactions count. HMRC treats several payments against one invoice as linked however long payment takes, and several separate invoices within a short period as linked too. No regime lets you reset the counter by splitting a sale.

4. Never tell the client you reported them. Tipping off is prohibited and criminally sanctioned wherever there is a reporting duty. Every regime protects a report made in good faith, even if nothing illegal is established.

What no regulator asks of you

Nobody sells you this part, because there is no revenue in it.

• No identity verification provider is mandatory anywhere. In-person identification, with a copy of the document and a record of the data, satisfies every regime on this page.

• No software is certified or required. Retention obligations are format-neutral.

• No automatic risk score is contemplated by any of these texts. The law asks you to assess a risk, not to accept an algorithm’s verdict. In an inspection, what counts is your reasoned judgement, and a risk level displayed by default on an empty file is the worst possible outcome.

Where to start if you have nothing

If you are starting from scratch, do three things in this order.

1. Write your risk assessment: which clients, which countries, which sales channels, which amounts, which means of payment. Every inspection starts here.

2. Write down who does what: who verifies identity, at what point, where the documents are kept, who decides in case of doubt, who files a report.

3. Train your team and keep the record. It is the easiest obligation to meet and the easiest absence to prove.

If you sell or exhibit in the UK, check your registration status with HMRC before anything else. It is the only obligation here that can be checked in a database.

What MARMALADE actually does

MARMALADE is management software for art galleries. It helps you keep a complete client file, follow cumulative amounts by counterparty and retain the documents, without ever assigning a risk level on your behalf.

First published on 9 September 2026, updated on 20 October 2026. It describes the law at the date of publication and is not legal advice.