Regulation Without Legislation: Combatting Money Laundering in the U.S. Art Market

By William Yuen Yee

Critics describe the art market as the “largest, legal unregulated industry” in the United States.^[1] Lawmakers have repeatedly introduced federal legislation to impose anti-money laundering (AML) obligations on U.S. art market participants (AMPs), without success. Most recently, the bipartisan Art Market Integrity Act, introduced in the U.S. Senate in July 2025, would impose AML obligations on most art market participants for sales of $10,000 per transaction and entities with annual sales exceeding $50,000.^[2] Such legislation follows other uphill attempts to impose stricter AML requirements on art market actors, including the 2019 COUNTER Act and the 2018 Illicit Art and Antiquities Trafficking Prevention Act.

However, the view that the United States does not regulate art transactions against money laundering is not entirely correct. Instead, different factors—industry self-regulation, public pressure from high-profile litigation and settlements, and sanctions laws—already de facto regulate the market.

The Art of Money Laundering