200 Fines, No Laundering: Is Art Market Regulation a ‘Good Thing’ Gone Far?

More than 200 UK art market participants have been fined since enforcement began in 2022 — and not one case involved actual money laundering. HMRC data, covering the period up to September 2025, shows the penalties landed on firms that simply failed to register or report material changes. One gallery was caught out on additional grounds: risk assessments, due diligence and staff training.

That figure sits at the centre of a new comment piece asking whether art market regulation has become too much of a “good thing”. The author's verdict is pointed: anyone calling the market unregulated “probably has not spent much time in an auction house compliance department.”

How thick is the rulebook?

At the major houses, those departments employ around half a dozen full-time staff. Their job is digesting what the piece calls an “expanding layer cake” of regulation across the EU and UK:

• money-laundering rules
• data protection
• import and export controls
• artist resale rights
• a growing economic sanctions regime
• endangered species rules
• firearms rules
• complex tax reporting

The UK adds obligations around ivory and annual “modern slavery” statements.

None of this looks objectionable at first glance. The author poses two tests. Does a regulation achieve its intended goal? And if it does, must it apply to every participant, up and down the market?

Who can absorb the burden?

The British Art Market Federation counted 167 laws and regulations affecting the UK art market in 2015. The federation's current chair, Tom Christopherson, says the impact has increased considerably since.

Sophisticated players — compliance teams, in-house lawyers — can spot trends and change course. Small fish cannot. The piece cites a London toy soldier shop, featured in a recent Financial Times story, among those fined.

The anti-money laundering regime itself arrived in 2020, extended to the art market by both the EU and the UK. The author, no fan of “dodgy dealings” stereotypes, writes: “I have yet to find convincing evidence of money laundering in the European art market that could have justified such an expansive regime.”

What counts as an offence now?

The scope stretches well beyond laundering. The art market is now a “regulated sector”, so failing to report suspicions — including activity that could conceivably fund terrorism — is a criminal offence. An east London art dealer was convicted under this “failure to report” offence in 2023 and sentenced to two-and-a-half years.

Sanctions add another layer, and it's thicker than checking names against a list of oligarchs. The UK's Russia sanctions list now covers nearly 2,000 individuals and 1,000 companies, with separate lists for Belarus, Iran and Libya — often under a multitude of transliterated names.

The Hauser & Wirth case

UK law also criminalises exporting or “making available” luxury goods, including art, to anyone “connected with Russia”. That offence was recently used to charge the gallery Hauser & Wirth and its shipping company. In July, Judge Tony Baumgartner of Southwark Crown Court dismissed the case: the prosecution had failed to prove the recipient was “connected with Russia”, since he no longer ordinarily resided there.

A charge against a global gallery, dismissed for want of a residence test. That tells you where the drafting strain shows.

The author concedes regulation's value in saving lives, protecting the environment and smothering criminality in high-risk markets. Whether every piece of it is justified for the art world, the piece concludes, “remains to be seen — or, rather, proven.” With enforcement now producing paperwork fines rather than laundering convictions, expect that argument to sharpen as the UK's AML regime comes up for review.