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 following month at a fair in London. Four jurisdictions, four sets of anti-money laundering rules, and no single answer to the question every gallerist eventually asks: what am I actually required to do?

This article maps the ground. Not because the rules are the same everywhere, but because the differences are smaller than they look, and the practical obligations converge on the same handful of habits.

One caveat before we start. What follows describes applicable law and cites its sources. It is not legal advice and does not replace a lawyer's view on your situation.

The United Kingdom is the strictest, and the only one with a register

If you sell art in the UK, or exhibit at a UK fair, this is the section that matters most.

Under the Money Laundering Regulations 2017, an art market participant is a business that trades in, or acts as an intermediary in the sale or purchase of, works of art where the value of the transaction, or a series of linked transactions, amounts to ten thousand euros or more. Freeport operators storing art above that value are covered too.

The obligation that has no equivalent elsewhere: you must register with HMRC. Not notify, not declare. Register, before carrying on business where a transaction of that size is likely.

This is not theoretical. HMRC began issuing fines in April 2022. Of 408 businesses penalised in 2023 for breaches of the regulations, ten were art galleries. Published fines have ranged from £1,250 to £52,000. Trading while unregistered is a criminal offence carrying up to two years' imprisonment, and the company, its senior managers and the staff involved are all potentially liable.

The trap for foreign galleries. An overseas dealer coming to the UK to sell at a fair falls within scope and needs to register with HMRC. If you exhibit at Frieze or TEFAF Maastricht's London counterparts and expect to sell above the threshold, registration is not optional because your business is elsewhere.

Artists selling their own work are outside the scope. Their representing gallery is not.

One change is coming. Following an eighteen-month consultation, HM Treasury indicated in July 2025 that the ten thousand euro trigger should be redenominated in pounds sterling. HMRC updated its guidance for art market participants in October 2025.

The European Union: same threshold, different implementations

The Fifth Anti-Money Laundering Directive brought art dealers into scope across the EU, with a ten thousand euro threshold applying regardless of payment method. That much is common ground. What each country did with it is not.

France transposed it in February 2020. Galleries are named in the monetary and financial code. The supervising authority 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 a prison sentence of six months to three years.

Spain is the outlier. Its law designates professional dealers in art and antiques as obliged entities without any transaction threshold at all. A Spanish gallery is in scope because of what it does, not because of what it sells for. Spanish law also requires that the person designated to liaise with the financial intelligence unit has received documented external training.

Cash payment ceilings vary wildly and have nothing to do with the ten thousand euro due diligence threshold. Spain sits at one thousand euros, France at one thousand, Italy at five thousand, while Germany, Austria and Ireland have no limit at all.

The United States has no rule for art, and that surprises people

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 directed a study of the wider art market. That study was published. No final rule for art dealers has followed.

This does not mean an American gallery has no exposure. Sanctions compliance applies regardless. Handling proceeds of crime is an offence with or without a sector-specific regime. And a US gallery selling to a European buyer, or exhibiting in London, steps into someone else's rules.

The practical consequence for a gallery selling across the Atlantic: 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 in itself. It is a reason to explain why you ask.

What stays the same everywhere

Strip away the jurisdictional detail and four habits survive in every regime.

Identify before you sell, not when you invoice. Every framework places verification before the transaction. It is the requirement most often missed, because it inverts the natural commercial reflex.

Know who is actually buying. Beneficial ownership identification is universal. When a company buys, the natural person controlling it must be identified. From July 2027 the EU threshold for that drops from twenty-five to fifteen percent, which will bring more people into view behind a corporate buyer.

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

Never tell the client you reported them. Tipping off is prohibited absolutely in every jurisdiction that has a reporting duty, and it is criminally sanctioned. Conversely, every regime protects a report made in good faith, even where nothing illegal is ultimately established.

What none of them require

This is the part nobody sells you, because there is no revenue in it.

No identity verification provider is mandatory anywhere. The compliance software market presents these services as though the law imposed them. It does not. In-person identification, with a copy of the document and a record of the data, satisfies every regime discussed here.

No software is certified or required. Retention obligations are format-neutral. A tool helps you sustain the process over years. It is not a condition of compliance.

No automatic risk score is contemplated by any of these texts. Many applications assign a calculated risk level on your behalf. It is convenient, and it is a trap. The law asks you to assess a risk, not to accept an algorithm's verdict. In an inspection what counts is your reasoned judgment, and a risk level displayed by default on an empty file is the worst possible outcome.

The date to have in mind

Regulation (EU) 2024/1624 applies directly across all twenty-seven member states from 10 July 2027, without national transposition. It replaces part of each country's rules with a single body of law, harmonises customer due diligence, lowers the beneficial ownership threshold to fifteen percent, and caps cash payments at ten thousand euros across the Union.

The UK, outside the EU, will not be covered. Which means a gallery selling into both markets will still be running two frameworks after 2027, not one.

Where to start

If you are starting from nothing, three things in this order.

Write your risk assessment. Which clients, which countries, which sales channels, which amounts, which payment methods. Every regime that inspects starts here, and it is the document that structures everything else.

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

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

And if you sell or exhibit in the UK, check your registration status with HMRC before anything else. It is the only obligation on this page that can be verified about you in a database, without anyone asking you a question.

MARMALADE is management software for art galleries. It helps maintain a complete client file, track cumulative amounts by counterparty and retain documents, without ever assigning a risk level on the gallery's behalf. This article describes the law applicable as at 9 September 2026 and does not constitute legal advice.