The Art Market Integrity Act (S.2400) introduced in the U.S. Senate in July 2025 is the major pending legislation extending the Bank Secrecy Act (BSA) anti-money laundering regulations to art market participants (AMPs). AMPs are broadly defined as “persons involved in the trade of works of art — including dealers, advisors, consultants, custodians, galleries, auction houses, and museums — or persons or entities acting as an intermediary in the sale or purchase of works of art.” AMPs are thus considered “financial institutions” under the BSA, mandating stricter customer due diligence for transactions of $10,000 or more and/or entities whose gross sales exceeded $50,000 in the prior year.
The Act defines “work of art” as “any original painting, sculpture, watercolor, print, drawing, photograph, installation art, or video art, not including — (A) applied art such as product design, fashion design, architectural design, or interior design; or (B) mass-produced decorative art, including ceramics, textiles, or carpets.’’
The Act follows the traditional four pillars of anti-money laundering (AML) protocols – creating internal controls, appointing a compliance officer, training, and independent testing – that apply to other covered financial institutions. The legislation is intended to include AMPs within the BSA’s AML and counter-terrorism financing regime, requiring measures including customer due diligence, record keeping and suspicious activity reporting. It directs the Treasury to coordinate with appropriate federal agencies revise its advisory issued (https://ofac.treasury.gov/recent-actions/20201030) by the Office of Foreign Asset Control on October 30, 2020, regarding the risks of high-value artwork transactions involving sanctioned persons or entities and further directs the Financial Crimes Enforcement Network (FinCEN) to develop proposed rules.
The Act seeks to bring US AML regulations of the art industry in line with the existing regulations in the United Kingdom and the European Union. In advance of US enforcement, international galleries and auction houses in the US have already adopted due diligence procedures including routine know your client (KYC) procedures and sanctions screening. KYC checks are a standard process in high value transactions even in unregulated industries. Buyers are often required to verify their identity, the source of funds, and past transaction history to prevent financial crimes. Such checks are not only important to make sure that these transactions do not facilitate money laundering, but to prevent fraud or other illicit activity. The checks may appear intrusive, but dealers and collectors need protection from unknowingly participating in criminal schemes. Verification is the best insurance against the risk of illegitimate financial sources.
You can start today to avoid the risk of being accused or tarnished by negligence or illegality. Our experts at Art Sales Vault can help you, now, with a thorough review of your transactions to flag unusual structures and check for red flags and sanctions. We can also help you create a customized company compliance policy. Effective due diligence is the best insurance policy.