Art, Money, and the Law: Sanctions & AML Enforcement in 2026
April 24, 2026
This panel discussion focuses on the trends and tools available to help art market participants stay compliant with AML regulations, navigate expanding sanctions regimes, and contribute to a more robust and responsible art market.
Russia’s full-scale invasion of Ukraine, now in its fifth year, has exacted a grave toll on Ukrainian lives and cultural heritage, while fundamentally disrupting European commerce. In response, art market participants have adapted their practices, most have accepted, if not always embraced, the need to scrutinize the source of funds and the ultimate beneficiaries of their transactions. Yet there is a growing sense that parts of the trade are holding their breath, waiting to see when they might safely return to dealing with the oligarchs who continue to fund the Russian war machine.
That moment is not coming. The UK’s regulatory environment is tightening, not loosening. The Money Laundering Regulations are at a critical juncture: the National Crime Agency has issued repeated alerts putting art market participants on notice of their AML obligations, while HMRC and the NCA have moved from guidance to enforcement, imposing penalties and opening high-profile investigations targeting fiduciaries and art market participants alike. OFSI’s 2025 threat assessment of sanctions compliance in the art market, alongside the 2023 MLR changes and the UK government’s demonstrated willingness to prosecute, signals that the direction of supporting Ukraine and policing the art trade is unambiguous.
For art market participants operating in the UK, compliance is no longer a peripheral concern, it is a legal imperative. Regulators are watching, the consequences of non-compliance are increasingly criminal rather than merely administrative, and private-public partnerships offer the most credible path toward a more resilient and trustworthy market.
Meet our Speakers:
Raminta Dereskeviciute focuses her practice on product compliance and trade regulation (sanctions and export controls). Raminta counsels clients on the EU and the UK sanctions regimes and export controls, including in higher risk jurisdictions such as Russia and Iran. Her experience covers the review and design of compliance programs, including giving training to client teams on controlled goods, prohibited jurisdictions, persons and activities. Raminta assists companies in liaising with regulators when assessing whether their activities are in breach of EU or UK sanctions regimes, or whether authorisations / licenses from the national authorities are appropriate. Raminta has participated as a chair and speaker on sanctions related panels at the Cambridge International Symposium on Economic Crime.
Rakhi Talwar is a compliance specialist with over twenty years of experience. Having begun her career in dispute resolution, she moved into regulatory compliance at DLA Piper in London, advising banks and major corporations on compliance programmes and regulatory matters. She subsequently held senior in-house roles at American Express and at Christie’s, where she built and led the auction house’s global compliance function over seven years.
Now working independently, Rakhi partners with businesses in the art and luxury sectors to design compliance programmes that not only manage risk but actively strengthen reputation and create commercial opportunity.
Yuliia Hnat, Co-Founder and Ecosystem Projects and Development Director of the NGO “Museum of Contemporary Art” (MOCA NGO).
Yuliia leads the Art Sanct initiative at the intersection of culture, law, and sanctions. She co-curated Navigating the War as Artists in Ukraine: A Practical Resource and has contributed to programmes on post-war memory culture. Previously, she held senior positions at the Ukrainian Institute and the National Art Museum of Ukraine.
Daryna Pidhorna, Lawyer and Analyst, Daryna is an expert specializing in the protection and preservation of cultural heritage during armed conflicts, as well as in the development and implementation of the right to truth. She is a member of the Expert Network of the Crimea Platform. Daryna has experience working with law enforcement agencies, government institutions, and international partners, including ICOM, UNESCO, Council of Europe, and the ICC. She holds a master’s degree in International Law from Taras Shevchenko National University of Kyiv and is currently pursuing a degree in Memory Studies and Public History at the Kyiv School of Economics.
Timothy Kompanchenko, Co-Founder & CEO, Bernard (AI for art, collectibles & real estate). Tim is a New York-based technology leader specializing in collectibles, art, and technology, with deep roots in the fine art world through trade services. Heis specializing in blockchain-backed provenance and art market data, and previously served as CTO at Christie’s for five years.
Moderator: Irina Tarsis. Irina is an attorney and the Founding Director of the Center for Art Law, a nonprofit institution with offices in New York and Zurich dedicated to advancing legal education and scholarship at the intersection of art, law, and cultural heritage. She advises artists, collectors, galleries, and institutions on a broad range of art law matters, and has built an international network spanning institutions and private collectors, curators, and attorneys across the United States and Europe. She is a frequent speaker, moderator, and commentator on issues of art market regulation, cultural property, and compliance.
About The Raphael Lemkin Society
The Raphael Lemkin Society is a non-governmental organization that brings together lawyers, researchers, cultural leaders, and human rights advocates to work toward preventing and punishing the crime of genocide. It’s work is grounded in the ideas of Raphael Lemkin, the lawyer whose work laid the foundations of modern international human rights law. He coined the term “genocide” and was one of the authors of the 1948 United Nations Convention on the Prevention and Punishment of the Crime of Genocide. The Society’s mission is to unite around Raphael Lemkin’s ideas to prevent the crime of genocide and ensure its punishment, with Ukraine as the precedent.
About “Museum of Contemporary Art” (MOCA NGO)
MOCA NGO is a cultural manager and expert in cultural policy and institutional development, focusing on memory, identity, and the role of cultural institutions in war and post-war resilience. Since 2020, MOCA NGO has been developing the Ukrainian Museum of Contemporary Art (UMCA) as a networked museum institution across Ukraine.
Following Russia’s full-scale invasion of Ukraine in 2022, within international partnerships, MOCA NGO has expanded its work to address the role of art in national security and international diplomacy. This includes advancing legal and ethical standards in the global art market, developing tools to trace looted cultural heritage and art assets linked to sanctioned actors, and strengthening technological capacities of Ukrainian museums to safeguard cultural memory.
About Our Host: McDermott
A full-service City practice with global reach, McDermott Will & Schulte’s London office delivers integrated legal solutions across corporate, finance, disputes, and regulatory matters. Drawing on an extensive international network, the team serves multinational corporations, financial institutions, high-net-worth individuals, and government bodies across the UK and worldwide.
The firm is recognised by Chambers UK and The Legal 500.
