EU To Downgrade Art Market Money Laundering Risk To“Moderate”
During this meeting, the Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA), which oversees EU banking and finance policy, presented key findings from its forthcoming 2026 Supranational Risk Assessment (SNRA) on money laundering and terrorist financing. The minutes indicate that this report will be published later in 2026. The new assessment categorizes the threat associated with artworks and antiques as“moderate” (level 2), a reduction from the previous“high” rating in 2022, citing“limited EU evidence.”
The minutes further detail that a moderate level means mitigation measures must be implemented and sector awareness improved. However, vulnerabilities persist, including the privacy and discretion of transactions, market accessibility, and jurisdictional fragmentation, all of which can facilitate illicit financial flows. In response, the Anti-Money Laundering Regulation (AMLR) has expanded the scope of regulated entities to include operators dealing in“cultural goods,” as defined by EU regulations. It also introduced a €10,000 cap on large cash payments to enhance transparency.
The SNRA identifies the secondary art market as particularly susceptible to criminal exploitation for money laundering, also assigning it a moderate (level 2) threat level. Alongside this downgrade, DG FISMA proposed several recommendations“aimed at mitigating risks and strengthening regulatory oversight” of the art trade. These include“continuous dialogue with stakeholders in the art and antiques markets, alongside awareness-raising campaigns, targeted training programmes, and the development of guidance and codes of ethics to promote compliance and best practices.”
The British Art and Design Association“welcomed the reassessment,” according to the minutes. However, the International Association of Dealers in Ancient Art, an industry group focused on antiquities, contested even the moderate risk assessment. They pointed to reports from the European Commission's Financial Intelligence Unit, which indicated that only 0.3 percent of art and antiquities items in the EU have been linked to criminal cases.
Source: ARTnews
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