On July 23, 2025, a group of U.S. Senators introduced the Art Market Integrity Act, a proposed law that would extend the Bank Secrecy Act (BSA) to the private art market. If passed, this legislation could dramatically reshape compliance obligations for art dealers, auction houses, and collectors across the United States. Let’s break down what it means, who it impacts, and why it matters for businesses operating in the art world.
What the Act Proposes
The Art Market Integrity Act is designed to close perceived “loopholes” in anti-money laundering (AML) compliance within the art and antiquities sector. Supporters argue it will help reduce financial crime and align the U.S. with international standards for screening art transactions.
As written, the law is broad. It applies to:
- Art dealers
- Auction houses
- Museums
- Collectors and advisors
Any single deal greater than $10,000, or annual transaction volume above $50,000, would trigger compliance obligations. Those covered would need to follow BSA policies and procedures, which include:
- Implementing risk-based AML programs
- Screening clients
- Documenting all transactions
Who’s Driving the Legislation?
The bill is championed by the Antiquities Coalition, a Washington, D.C., nonprofit focused on combating “cultural racketeering.” The group has long argued that the art market represents a weak spot in the global financial system, what it describes as a “sanctions black hole.”
The Critics’ View
Not everyone agrees that the art market is a hotbed for money laundering. Organizations such as The Authentic Tribal Art Dealers Association, argue the legislation is a “missile looking for a mouse,” and they question whether the art market truly poses a major money laundering risk.
Their concerns center on three key points:
- Minimal risk: Compared to banking, real estate, or crypto, money laundering through art is rare and small in scale
- High burden: AML compliance programs, software, and staffing could overwhelm smaller galleries and independent dealers.
- Duplication: Because most art transactions already flow through banks (which are themselves subject to BSA rules), critics argue the law adds little extra protection.
In fact, in 2022 the U.S. Treasury Department concluded that the art market should not be an immediate focus for new AML/CFT requirements.
The Bigger Picture
The bill reflects a broader global trend: more economic activity is falling under the umbrella of anti-money laundering and counter-terrorist financing (AML/CFT) oversight. While oversight is important, proportionality matters.
- The fine art market is niche, with relatively low transaction volume compared to global finance.
- Laundering money through physical goods that must be shipped, stored, and insured is hardly the easiest route.
That said, the proposed thresholds of $10,000 per transaction or $50,000 annually are low by fine art standards. Even mid-range works often exceed those values. This means compliance obligations would extend beyond major auction houses to include smaller and mid-sized dealers and galleries as well.
What This Means for the Art World
If passed, the Art Market Integrity Act would significantly reshape compliance obligations across the art market. It would introduce new costs, new processes, and a steep learning curve, particularly for businesses unfamiliar with formal AML programs.
For compliance professionals, family office advisors, and art market professionals, now is the time to monitor this legislation closely. Regardless of whether it becomes law, the proposal signals a shift in how regulators view the intersection of art and finance.
Final Thoughts
Is the Art Market Integrity Act a necessary safeguard or an unnecessary burden? The answer depends on perspective. What is clear is that regulators are taking the art market more seriously, and businesses must be ready.
For art dealers, auction houses, and collectors, now is the time to assess compliance readiness. Tailored compliance strategies can help manage risk without overwhelming smaller operations.
You don’t have to navigate this intersection of art, finance and compliance alone. I help clients across industries, including art, finance, and emerging markets. I design risk-based AML programs that are practical, cost-effective, and tailored to their operations. Whether you’re preparing for new legislation or simply want to strengthen your compliance framework, I can help you implement the right controls without overburdening your business.
📩 Contact me today to learn how to build AML compliance programs that protect your reputation and keep regulators at bay.