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A Case for the Art Market Integrity Act

August 30, 2026

Photo: I. Tarsis, Art Fair Blur

By Victoria Cook

Center for Art Law 2025 Art Market Integrity Act Bill — The proposed “Art Market Integrity Act” (2025).

The United States accounts for the largest share of the global art market, and yet remains conspicuously absent from the international regulatory consensus on Anti-Money Laundering (AML). Efforts to address this issue, most recently through the Art Market Integrity Act (AMIA), introduced as S. 2400 in the Senate in 2025, would close that gap by bringing U.S. art market participants (AMPs) under the same kind of oversight already applied in the EU and U.K.. The 2025 bill has faced pointed criticisms including the cost to small businesses and collectors, the scale of the underlying risk, and the motivations of some of its advocates. But evidence from comparable jurisdictions and US regulatory findings suggest these concerns, while legitimate, do not outweigh the case for greater oversight. The AMIA offers tangible benefits for the art market: greater regulatory uniformity, transparency, and enhanced record-keeping that would, at long last, deny easy access to a historically opaque trade.

Background on Money Laundering and the Art Market

The art market has repeatedly been exploited to conceal illicit funds and finance criminal activity. For example, the Islamic State of Iraq and Syria (ISIS) monetized looted antiquities to generate untraceable revenue.^{^[1]} Beginning in 2014, ISIS looted and destroyed protected cultural heritage sites, selling the looted antiquities to international art collectors and using the proceeds to further terrorist activities. This practice was further evidenced in May 2015, when a raid in Eastern Syria against senior ISIS finance official Abu Sayyaf, resulted in the recovery of a significant cache of archeological artefacts.^{^[2]}

More recently, the lack of transparency in the art market has raised concerns about the ability of sanctioned individuals to conceal assets. A bipartisan U.S. Senate Permanent Subcommittee on Investigations report published in 2020 found that the market’s opacity had allowed sanctioned persons to purchase $18 million in high-value art through shell companies in the U.S.^{^[3]} The Report detailed how the sanctioned parties, Arkady and Boris Rotenberg, were able to move $91 million through the U.S. financial system using these companies.^{^[4]}

These cases illustrate the broader vulnerability of the art market to money laundering.^{^[5]} Criminals can and have used art transactions to introduce illicit funds into the legitimate financial system. This can occur when artwork is bought with illegally obtained funds and later resold for a profit, or when such artwork is used as collateral for a loan.^{^[6]} Several features of the purchase and transfer of art make it particularly attractive for this purpose. Artworks concentrate substantial value into a single portable asset, and their value can be subjective and difficult to independently assess.

Up until recently, individuals could purchase anonymously or through intermediaries who are not required to disclose the final buyer.^{^[7]} When the identity of an artwork’s true owner is concealed, it becomes considerably more difficult to determine the source of the funds or whether the transaction was legitimate.^{^[8]} The international nature of the art market can further complicate efforts to trace transactions across jurisdictions.

Coupled with the scale of the art market, rising to $59.6 billion in sales in 2025, the culture of privacy and reliance on third-party intermediaries have contributed to the longstanding concerns about the use of the art market to launder money and finance terrorism.^{^[9]} The scale of the illegal trade in art and antiquities further underscores these concerns. In 2011, The United Nations Office on Drugs and Crime (UNODC) estimated that up to $6.3 billion could have been laundered through the trafficking of cultural artifacts. However, estimates of the value of the illicit art trade range from several hundred million to billions of dollars annually, with an exact figure being difficult to determine.^{^[10]}

Current Anti-Money Laundering Frameworks:

International Approaches

In 2018, the European Union (EU) enacted its 5^th AML Directive, adding the art market to the EU’s AML regulations.^{^[11]} The decision was prompted by the concern about the rise in terrorism throughout the 2010s, and terrorists’ use of the art market to launder funds garnered from corruption. To combat this threat, all EU member states were required to enact their own AML legislation targeted at the art market.^{^[12]} Given the size of the European art market, and that many EU member states, like France, are significant players in the global art market, the directive served as an important step towards preventing overall art market abuse.

The United Kingdom (UK) has also adopted strict AML regulations, subjecting AMPs to extensive rules and requirements.^{^[13]} These regulations were expanded in 2020 as a result of the introduction of the Money Laundering Regulations 2017. AMPs who trade in or act as intermediaries in the sale of art worth EUR 10,000 or more are required to take additional measures to prevent money laundering, including identifying the individual or entity involved in the transaction and reviewing their intentions.^{^[14]}

To help AMPs navigate these new obligations, several educational and trade associations have produced compliance resources. Center for Art Law, together with other organizations, produced an AML and the Art Market Study (now in its 2nd Edition) to help AMPs better understand jurisdiction specific compliance requirements. Other resources include the Responsible Art Market Initiative in Geneva, Switzerland and British Art Dealers Association Anti-Money Laundering Tool Kit.

United States Framework

According to the Art Basel and UBS Global Art Market Report 2026, the US holds the largest share of the international art market accounting for 42.3% of global sales.^{^[15]} Despite this statistic, the government has been hesitant to enact AML legislation targeted towards the art market. Nevertheless, the US has developed an extensive federal AML framework that applies broadly across the financial sector.The Bank Secrecy Act (BSA), which was passed in 1970, is the primary mechanism the U.S. government uses to regulate money laundering. The act requires financial institutions to take steps to detect, prevent, and report financial crimes such as tax evasion and money laundering.^{^[16]} Financial institutions must file a Currency Transaction Report (CTR) for any single or aggregated cash transaction that exceeds $10,000.^{^[17]}

The BSA was most recently modified with the introduction of the Anti-Money Laundering Act of 2020 (AMLA), imposing further reporting requirements for antiquities dealers including recording and reporting suspicious transactions.^{^[18]} The AMLA also directed the Department of the Treasury to conduct a study on money laundering risks in the high value art trade and report back with recommendations. Despite this, art market participants who do not deal in the trade of antiquities remain largely exempt from these requirements.^{^[19]}

Art Market Integrity Act

The AMIA is a bi-partisan bill introduced by Senators Chuck Grassley and John Fetterman in July 2025 to fill the gap that was left when the BSA was modified by the AMLA. The proposed act would expand the definition of “financial institution” to include art dealers, galleries, auction houses, museums, advisors, custodians, and collectors.^{^[20]} Covered parties would be expected to undertake record keeping, reporting, customer due diligence, and other requirements. Additionally, people engaged in the trade of art would be expected to file CTRs, Suspicious Activity Reports (SARs), and participate in customer identification programs.

The bill is carefully scoped, exempting artists selling their own work, businesses conducting less than $50,000 in annual art transactions, or no individual sale over $10,000 in a fiscal year and non-profit entities.^{^[21]} Furthermore, the definition of “art” is relatively narrow, including painting, sculpture, watercolor, print, drawing, photograph, installation art, or video art, but not applied art or mass-produced decorative art.^{^[22]}

What the AMIA Would Achieve

Beyond extending the definition of financial institution under the BSA, the AMIA provides tangible benefits for both AMPs and the broader art market. Passing the AMIA would not only close the regulatory gap in the US, but would also contribute to regulatory uniformity between the domestic art market and other major art markets in the EU and the UK.^{^[23]} Given that the US has the only remaining unregulated major art market, there is a concern it may attract funds that other jurisdictions now screen more closely. Uniformity prevents “cross-border regulatory arbitrage” and the US from becoming a jurisdiction of choice for illicit art trafficking.^{^[24]} Therefore, the AMIA would protect national security and maintain the legitimacy of the US art market.

Another clear benefit of the AMIA is improved transparency. Though AMPs will face increased reporting requirements under the act, these obligations will provide them with greater insight into the parties with whom they transact. Historically, the opacity of the art market has allowed individuals to launder money undetected and evade sanctions. Requiring AMPs to identify and understand their clients makes it less likely that priceless works of art will fall into the wrong hands. This requirement also protects AMPs, whose reputations are integral to their standing in the art market, from being caught up in a scandal.

Furthermore, increased reporting doesn’t just deter criminals and improve transparency, it creates a paper trail that benefits law enforcement. SARs and CTRs, which some AMPs will be required to produce if the AMIA is passed, create a record which law enforcement can use to trace a transaction. If a transaction is later found to be connected to money laundering or sanctions evasion, these reports provide authorities with information that may be otherwise difficult to obtain with the present emphasis on privacy. Not only would the AMIA discourage bad actors from abusing the art market, but it would also increase the likelihood that illicit activity would be detected.

Criticisms of the Art Market Integrity Act

One of the AMIA’s most vocal critics has been Cultural Property News, an organization focused on issues affecting the art market and sponsored by the Committee for Cultural Policy (CCP). Its critique largely centered on the Antiquities Coalition, another nonprofit with a mission to protect “shared heritage and global security,” who has been a prominent advocate for the AMIA.^{^[25]} Cultural Property News questions whether the Antiquities Coalition’s support for the AMIA is driven by regulatory concerns or whether it reflected the organization’s longstanding advocacy on cultural heritage issues.^{^[26]}

Cultural Property News also raised concerns about the potential burden of the AMIA on small businesses, museums and collectors, arguing that its due diligence requirements could impose disproportionate compliance costs on those without the resources of larger galleries and auction houses.^{^[27]}It further questions whether these burdens are proportionate to the scale of the problem, pointing to the Department of Treasury’s 2022 study, which concluded that the art market should not be an immediate priority for comprehensive AML regulation.^{^[28]} Lastly it challenges the purported link between the sale of antiquities and terrorist financing, arguing the widely stated estimates have largely overstated the problem.^{^[29]} While these concerns warrant consideration, the evidence presents a more nuanced picture than Cultural Property News suggests.

Assessing the Criticisms

The Antiquities Coalition Debate

While Cultural Property News presents a detailed and extensively researched critique of the act, much of its analysis was directed towards the advocacy efforts and perceived motivations of one of the bill’s most prominent supporters, the Antiquities Coalition. Their broader mission is to protect cultural heritage and global security, having been longstanding advocates for greater regulation of the art market. The Coalition has also undertaken significant research on the vulnerabilities of the art and antiquities trade, providing actionable recommendations to address some of the most pressing issues facing the market today. Consistent with these objectives, the Coalition has also advocated for the passage of the AMIA.

Chair and Founder of the Antiquities Coalition, Deborah Lehr, described the AMIA as a “smart, pragmatic, and long-overdue step to protect a multi-billion dollar industry from criminal abuse.”^{^[30]} She also noted that the legislation will “help preserve the integrity of the market” and “keep the U.S. a competitive and trusted leader in the global art and antiquities trade.^{^[31]} These are legitimate objectives. The Coalition’s broader work demonstrates that their advocacy is rooted in their knowledge of the vulnerabilities of the art market and potential ways to address them. The illicit trafficking of cultural property is a pressing issue and efforts to improve the integrity of the art market should not be dismissed simply because they are supported by an organization advocating for better regulation.

Moreover, the motivations behind the Antiquities Coalition’s support of the bill and the AMIA itself cannot be conflated. Despite the motivations of individual advocates, the need for greater regulation comes from the vulnerabilities of the art market. Even if every criticism offered by the Coalition is accepted, it would not prove that the bill is unsound. The merits of the AMIA should instead be evaluated on the basis of its provisions and likely effects rather than the alleged motivations of one of its advocates. Given the concerns shared by many small American businesses and art collectors, maintaining this distinction becomes particularly important.

What the Treasury Reports Actually Found

Center for Art Law 2022 Treasury Report Art Market

In 2022, the Treasury Department published its study of the Facilitation of Money Laundering and Terror Finance Through the Trade of Works in Art. The report’s final conclusion stated that the art market should not be an immediate focus of comprehensive AML regulation.^{^[32]} However, this conclusion did not stem from the fact that the art market poses a low risk, as some critics seek to suggest.

The study concluded that AMPs who regularly transact in high-value artworks have inherent qualities that make them potentially vulnerable to being exploited as conduits for money laundering and other financial crimes.^{^[33]} The particular risks posed to AMPs were broken down by sector. While the risk posed to galleries and art fairs was low, auction houses, online marketplaces, museums, non-profits, and art finance companies were found to be potentially vulnerable.^{^[34]} Therefore, the study did not find there was no risk, but rather suggested a prioritization of regulation efforts to areas deemed more vulnerable.

The findings of the 2022 study also addressed the relationship between high value art and terrorist financing. The study found the risk posed by terrorist financing in the art market was low across all sectors.^{^[35]} Though terrorist financing was a prominent concern in the early 2010s, the AMIA and other similar regulations have not been enacted to solely or primarily address terrorist financing concerns. This finding narrows the terrorist financing case specifically, but does not extend to the art market’s risk overall, which is what the AMIA is designed to target.

It must also be noted that the 2022 report is not the most recent Department of Treasury Report. The Treasury’s subsequent 2024 National Money Laundering Risk Assessment (NMLRA), put a greater emphasis on the art market’s vulnerabilities. While the study noted little change in the art market’s risk profile, it emphasized the increasing use of art as a financial asset.^{^[36]} Overall, the study held that the art market was vulnerable to abuse and faced unique challenges in investigation. The recent 2026 NMLRA doubled back on these claims, suggesting that the art market poses less of a threat but remains susceptible to the risk of money laundering.^{^[37]} The evolution of the Treasury’s assessments suggest that reliance upon the 2022 assessment alone is misplaced.

Lessons from Existing AML Regulation

One of the primary criticisms is that implementing the AMIA will destroy the art market and force small businesses to shut down. But this concern is a greatly overstated doomsday scenario. AMPs, like other individuals and businesses, are already subject to federal anti-money laundering statutes under the United States Code (USC). Either knowingly conducting a financial transaction involving proceeds of unlawful activity or knowingly engaging in a monetary transaction over $10,000 involving property derived from unlawful activity could lead to a criminal conviction.^{^[38]} In some cases, deliberate avoidance of knowledge or “willful blindness” can satisfy a statutory knowledge requirement.^{^[39]} As a result, the additional due diligence requirements that will be imposed under the AMIA will not represent an entirely new compliance burden from what diligent AMPs already undertake to avoid criminal conviction. The AMIA will therefore primarily affect larger actors engaged in more substantial transactions and those who have failed to meet basic due diligence requirements already.

Moreover, comparable AML regulations already in place in Europe and the U.K. suggest that the introduction of new guidelines will not impose an unmanageable burden. The art markets have continued to operate despite the introduction of these requirements. Sales in the U.K. reached $10.5 billion in 2025 and France, who is the largest player in the EU art market, had $4.5 billion in sales in 2025. When the 5^th AML Directive in the EU took effect, art market growth slowed slightly as AMPs adjusted their operations to comply.^{^[40]} But ,that initial dip is now viewed positively and considered necessary to ensure the art market was better regulated and more secure.^{^[41]}

The experience of the European and U.K. markets also suggests that initial concerns about AML compliance may diminish as AMPs adjust to the requirements. When AML regulations were first introduced in the EU and U.K., they were among the primary challenges faced by dealers and auction houses in their daily operations.^{^[42]} By the 2026 report, however, the primary concern of mid-tier auction houses and dealers was political and economic volatility, with AML compliance no longer featuring a standalone concern.^{^[43]} The U.K. offers a further data point. As of March 2025, 1,337 art market participants were registered with His Majesty’s Revenue and Customs (HMRC), a significant increase from the 208 registered in 2020.^{^[44]} Rather than driving participants out of the market, the regulation appears to coincide with an increase in registered participants.

The Changing Cost of AML Compliance

Critics’ concerns over the costs of compliance also overlook how quickly this landscape is evolving. While AML compliance initially required substantial investment, advances in technology have reduced those costs. Most of the compliance costs stem from manual processes including verifying documents, cross-referencing watch lists, and reviewing previous accounts. Software Application Programming Interfaces (APIs) have since automated many of the necessary steps, making it possible to reclaim between 60 to 80% of compliance costs.^{^[45]} Some providers have also moved away from fixed subscriptions or in-house compliance staff, instead offering pay-per-check models.^{^[46]}

Another frequently cited concern is that all financial institutions under the BSA are treated the same. This concern fundamentally misunderstands the structure of the BSA framework. The BSA establishes broad statutory requirements, but FinCEN and other federal regulators are responsible for tailoring how those requirements apply across sectors. As a result, banks, casinos and other covered institutions do not operate under identical AML compliance regimes.^{^[47]} Moreover, the regulatory framework is increasingly risk-based and proportionate, with institutions directed to allocate compliance resources towards higher-risk customers and activities. In April 2026, FinCEN proposed further reforms to strengthen this proportionate approach, emphasizing programs that allow financial institutions to devote resources to higher-risk areas, while reducing unnecessary compliance burdens.^{^[48]} If AMPs were brought under the BSA, they would be expected to design programs proportionate to the risk their transactions pose. A small art dealer would therefore not necessarily be subject to the same strict requirements as an auction house or museum. These developments suggest the costs of compliance may not be as high as critics anticipate.

Conclusion

The lack of comprehensive AML regulation in the largest art market in the world leaves the U.S. vulnerable to significant financial and national security risk. The AMIA would address important gaps in the existing regulatory framework while aligning U.S. compliance requirements more closely with those of other leading art-market jurisdictions. The burdens imposed during early implementation of the act do not outweigh the broader benefits that greater transparency and accountability will allow. Enacting the AMIA would be an important step toward strengthening the integrity of the art market, protecting cultural property, and developing greater regulatory uniformity.

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Disclaimer: This article is for educational purposes only and is not meant to provide legal advice. Readers should not construe or rely on any comment or statement in this article as legal advice. For legal advice, readers should seek a consultation with an attorney.