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AML and the Art Market Study (2025 edition)

October 2, 2025

Front page Center for Art Law AML study 2025

About the Study

From 16 in the first edition to 28 countries in the second. From 78 pages in 2023 to over 200 pages in 2025, the Center is pleased to share the 2nd edition of its Anti-Money Laundering Study for the Art Market participants. When we produced the 2023 study, we knew that the limited scope of jurisdictions would need to grow to incorporate and reflect the international nature of both art and money laundering. As promised, we continued to build upon the original effort and plan to provide our readers with a growing survey in the future that breaks down the AML practices worldwide. In the 2nd edition, the readers can expect to see new jurisdictions, as well as updated and expanded list of questions and answers, and relevant secondary resources that have been provided by the generous and patient volunteers, interns, and advisors to the Center for Art Law.

We cannot thank our contributors enough for their time and expertise in putting together this valuable source of information. We believe that their insightful and comprehensive answers will result in a more informed and responsible art market environment.

THANK YOU TO ALL THE VOLUNTEER ATTORNEYS WHO CONTRIBUTED TO THIS RESOURCE:

(Argentina) Juan Javier Negri, Negri & Pueyrredon Abogados, Buenos Aires
(Australia) Alana Kushnir and Liliia Kruglova, Guest Work Agency, Melbourne
(Austria) Dr. Peter M. Polak, Founding Partner at Polak & Partner Rechtsanwälte GmbH
(Belgium) Oliver Lenaerts, Contour Law, Brussels
(Brazil) Fausto Martin de Sanctis, Federal Appeals Judge, Sáo Paulo
(Bulgaria) Slavi Mikinski, Mikinski & Partners Law Office, Sofia, Dilyana Bozhkova, Deloitte
(Canada) Paul E. Bain and Nicholas J. Tkach, Dickinson Wright LLP, Toronto
(Croatia) Jakov Mamic, Mamić Grigić Vinter Attorneys at Law LLC and Tea Vuletin, Ilej Partners, Zagreb
(Denmark) Frederik Thufason and Tilde Weidinger, Accura, Copenhagen
(Finland) Anette Alén, Professor of Civil and Commercial Law, Helsinki
(France) Noor Kadhim, Fieldfisher; Anne Sophie Moreau and Camille Merlier, Borghese Associes, Paris
(Germany) Katherina Garbers-von Boehm, Onto Partners, Berlin
(Greece) Stelios Gregoriou and Evangelia Grigoriou, Gregoriou Law Firm, Athens
(Hong Kong) Monin Ung, MUNG, Hong Kong
(India) Pallav Shukla, Srishti Khare and Raashika Kapoor, Trilegal, New Delhi
(Italy) Alessandro Gai and Massimo Sterpi, Gianni & Origoni, Rome
(Luxembourg) Eléonore Moreau-Gentien, MOLITOR Avocats à la Cour SARL, Luxembourg City
(Mexico) Diana Rangel León, Basham, Ringe and Correa, Mexico City
(Netherlands) Laurens Kasteleijn, Art Law Services, Amsterdam
(Poland) Filip Radzikowski – original submission
(Portugal) Susan J. Mumford, ArtAML, London
(Romania) Dr. Mihaela Mocanu, CMV Law practice, Bucharest
(Spain) Gunna Freivalde, AMG Attorneys S.L, Madrid
(Sweden) Hans Eriksson, Westerberg & Partners Advokatbyrå AB, Stockholm
(Switzerland) Annatina Menn, Uto Legal, Zürich
(U.K.) Rakhi Talwar, RTalwar Compliance, London
(Ukraine) Polina Ivko, Adwar Ivko, New York
(USA) Olivia Taylor, Pryor Cashman, New York

Readers are invited to review the responses and study AML regulations in their respective jurisdictions as well as compare differences in practices. As the legislative landscape is continuing to evolve, readers should monitor changes and consult relevant authorities and experts.

Special Thanks to the Center’s Team Members:

We would also like to express our gratitude to the following team members and advisors for their invaluable support in working with the attorneys and in bringing the 2nd edition together:

Our Fall 2024 Interns — Emily Yan, Emily Finch, Athena Lunau, Lydia Filipsson*
Our Spring 2025 Interns – Natalie Steingard, Emily Ko, Devin Dowing
Our Summer 2025 Interns – Juliette Groothaert*, Kaede Kusano, Shelby Jorgensen, Justine Chen

*Project Leads

Rachel Sundar, Post-Graduate Fellow (Summer 2024)
Poppy Kemp, Post-Graduate Fellow (Summer 2022)
Irina Tarsis, Board of Directors
Atreya Mathur, Director of Legal Research
Rakhi Talwar, Ad Hoc Advisor
Andrew Adams, Advisory Board

You can access the 2nd Edition of our Comparative Study HERE.

nB: There are a number of jurisdictions that we would like to add in the next report. Attorneys and academics working in the missing jurisdictions please reach out to assist us with our report and ensure it is as informative as possible. If you know of an attorney that may be able to help, please nominate them and we will ask for their assistance.

2025 Edition