It is fair to say that compliance and regulation firmly captured the art world’s attention in 2025. High-profile court cases involving blue-chip galleries, the prosecution of a well-known television art dealer, HMRC fines exceeding £150,000, and talk of a new US bill targeting money laundering in the art market, have all contributed to a sense of change.

Yet beyond the headlines, 2025 also marked a turning point of a different kind. Across the sector, there was growing confidence in how compliance can be approached practically, proportionately and as part of a broader approach to good governance.

‍

Here’s our guide to keeping compliance simple, in 2026:

‍Absorb the learnings from last year

Arguably, the most important lesson from 2025 is that enforcement is real and escalating. In the UK, HMRC issued fines to several art market participants, not only for failure to register on time as an Anti-Money Laundering (AML) regulated business, but also for lacking the required processes and failing to provide timely updates. 

High profile court appearances were a potent reminder that indirect exposure to risk, such as selling on behalf of intermediaries, trusts, or offshore companies, could create substantial legal challenges, if beneficial owners were not properly identified and screened.

Regulations were also tightening. The UK expanded its financial sanctions reporting regime to include art market participants, whilst the EU’s regulation (2019/880) on the import of cultural property came into effect, requiring more detailed provenance documentation for antiquities and artworks imported into the EU.

In the US, legislative activity began to push domestic legislation in line with international AML, with the Art Market Integrity Act, which would bring the art market into the country’s broader AML and counter-terrorism financing obligations.

‍

Looking forward to 2026

In 2026, art businesses should watch for expanded regulatory scope and enhanced enforcement, with more proactive inspections anticipated across all scales of business.

With shifting and growing momentum and attempts to better align art market regulation internationally, particularly between the UK, EU, and US, businesses operating across borders may face overlapping obligations and should avoid assuming that compliance in one jurisdiction is sufficient. Given the volatile and ever-changing nature of sanctions, the need for real-time or at least regular checks needs to be built into day-to-day business on a pro-active basis.

Fortunately, digital advances, combined with a growing recognition of the value of collaborative due diligence, are creating opportunities for businesses to address these challenges more effectively. 

We are already seeing this shift in practice, with shared reports and reviewing previous approval rates becoming central to how galleries manage their due diligence. In a sector that has long relied on networks to thrive, having tools that allow galleries to support each other is a major focus for 2026.

‍

Good practices to embed this year

Art businesses should enter 2026 with clear, documented compliance frameworks in place. Here’s a quick checklist to make sure you’re up to speed:

1. Make sure you’ve got the basics right, ensuring you are doing due diligence on all transactions above €10,000. If you are unsure if you’re doing this right, get in touch and we are happy to help you audit your approach.

2. Update any documents and procedures in line with recent changes. It can be easy to miss changes to regulation (e.g. the recent changes to UK sanctions) and it’s important that you are understanding and updating your process in line with the latest news.
   
   
3. Ensure everyone who manages transactions has a clear understanding of their obligations. Policy documents and risk assessments are only helpful when they inform your actual day to day practice (regulators will check you understand your documents during an intervention).

4. Make the most of Arcarta to help keep things simple. We have released a number of major updates in the last year, from smart request forms to predictive due diligence. Making the most of these new tools can help you spend less time on compliance and more time on the things that really matter.

‍

And finally, if you have any questions or concerns, we are at the end of the phone and are happy to support you with a complimentary consultation.

‍