“The size of the sector, combined with a previous lack of consistent regulation, means that the global art market has been an attractive option for criminals to launder money,” the Treasury’s risk assessment said.

As a high-risk threat, sellers must follow new rules, including registering with HM Revenue & Customs (HMRC), writing a risk assessment to indicate how exposed they are to money laundering and carrying out customer due diligence before closing a deal. transactions.

“Art moves easily across borders. That’s the great advantage of art: a house in central London is a good investment, but you can’t take it with you,” explains Angelika Hellwegger, legal director at law firm Rahman Ravelli.

And although the rules started a few years ago, this year HMRC has stepped up the pace of compliance. “As a company, we’ve had around three times as many clients receive interventions from HMRC so far in 2024,” said the art and anti-money laundering expert.

“Looks like the honeymoon period is over. The pace has certainly quickened, both in the number of galleries investigated and in the rigor of implementation. Previously, they would ask, “Are you registered and doing the basics?” And now their questions are much more aggressive and assertive.”

The financial penalties have already been paid. Under the new regulations, between 2021 and spring 2023, 31 art market participants were fined for failing to register with HMRC. Between spring and autumn 2023, 32 fines were issued. Figures for 2024 have not been made public, but art market participants are talking about an even greater intensity.