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In addition to the existing AML reporting and recording obligations, UK AMPs will soon be subjected to sanctions regulations. Sanctions compliance is a separate and parallel obligation to the AML regulations. It applies regardless of whether a transaction meets the €10,000 AML threshold and is entirely outside the AML framework.
New Anti-Money Laundering regulations in the United States may be closer to a reality. If the Art Market Integrity Act (S.2400) is passed, it will bring the US regulatory environment in the fine art industry in line with Europe.
The Treasury conducted a study on how the Art Market and those who transact within it are most at risk to be involved with money laundering.
While the road to passage for the ENABLERS Act may face obstacles along the way, what is clear is that it is not a matter if these types of regulations will come into force, but when.
British Art Market Federation Confirms U.S-based art dealers must register with the HMRC prior to transacting in the UK, and other updates.
The ENABLERS Act, approved by the US House of Representatives and set to pass as a part of the annual defense budget, expressly requires certain professionals to comply with Anti-Money Laundering regulations.
The HMRC has indicated that they may be conducting compliance checks at upcoming fairs or via written communications with participating art market professionals that fall under the regulations.
The opaque nature of the world art market has made it an attractive and effective mechanism for masking criminal activity.
As a US-based art industry professional, buying or selling a work of art in the UK or the EU, you are required to comply with the local law. If you don’t you may be barred from such transactions in the future.