Art & specie

Written by Karen Barnard-Taylor

 Key developments in 2025

In 2025, art businesses face heightened scrutiny under anti-money laundering (AML) regulations, reflecting global efforts to combat financial crime. Regulatory compliance has continued to evolve since January 2020 when Art Market Participants (AMPs) became subject to obligations under the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017 and now demands robust due diligence, transparent provenance documentation, and vigilant monitoring for links to sanctioned individuals or entities. From 14 May 2025, high value dealers and AMPs are also legally required to comply with financial sanction reporting obligations in the UK.

In July 2025, HMRC published their latest fines. This shows that the number of fines as well as the scale of penalties is on the rise.  Where previously many of the fines resulted out of a failure to register with the HMRC, 2025 has seen fines for wider ranging breaches such as a failure to notify HMRC of a material change, inadequate risk assessments, poor customer due diligence and poor record-keeping.

Provenance and ownership claims are central to both regulatory compliance and insurance underwriting. Insurers increasingly require evidence of clean title and a documented transaction history to assess risk profile. Items with opaque ownership structures, links to high-risk jurisdictions, or histories of illicit transactions may trigger enhanced due diligence requirements or outright refusal of cover. Underwriters will seek assurance that items have not been involved in AML breaches or sanctions violations, as this could compromise insurability and expose insurers to regulatory penalties. Where such issues are identified, insurers may refuse coverage to avoid reputational and legal risk.

The British Art Market Federation has guidance on anti-money laundering for AMPs, which emphasises the importance of and requirements for, policies, controls and procedures, training, CDD, adequate record keeping and risk assessments to mitigate exposure.

What to look out for in 2026

Notwithstanding the increasing focus by regulators into this market, 2026 will continue to see an increase in investment in high value art as it is widely regarded as resilient to inflation. Whilst the most recent report by the Art Basel and UBS Survey of Global Collecting showed a decrease in overall sales, this was predominantly due to economic challenges. However, the report also showed that High Net Worth Individuals allocated 20% of their wealth to art in 2025, which is an increase from 15% in 2024.Unlike financial investments, fine art is less correlated with traditional markets and offers diversification and allows the investor to hedge against economic volatility. Its rising popularity is driven by increased global wealth, expanding interest from younger collectors, and the emergence of art as a status symbol and alternative investment resilient to inflation.

New collectors are reported to be more likely to buy online, which offers benefits such as convenience, choice and transparent pricing.  New collectors are discovering artists through digital channels and are sourcing art through social platforms.  Buying online makes it difficult to assess detail, and it can be difficult to verify authenticity.  An increase in counterfeit claims is in part due to the growth in online purchases.  Collectors buying online must take care to ensure that they verify the identity of the seller and obtain a detailed provenance for the work. The rise of digital platforms and technologies will continue to assist, and despite the risks, online purchases will remain an increasingly popular choice.