EU Set to Downgrade Art Trade's Money Laundering Risk Rating

By Daniel Okafor

The European Commission plans to downgrade its assessment of the money laundering and terrorist financing risk posed by the art and antiquities trade, the Financial Times reports. The new rating is "moderate". In 2022, the same assessment called the threat "high".

The downgrade has not been finalized. A Commission spokesperson told the FT as much. But the paper pointed to publicly available minutes from a January 29, 2026, meeting in Brussels of the Commission's Expert Sub-Group on Dialogue with the Art Market. Minutes, like drafts, have a way of speaking plainly.

What does the new rating mean?

At that meeting, the Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) — the Commission department responsible for EU banking and finance policy — presented key findings from its upcoming 2026 Supranational Risk Assessment (SNRA), the EU's periodic review of money laundering and terrorist financing threats. The report will be published in 2026.

The SNRA rates the threat linked to works of art and antiques as "moderate" (level 2), down from "high" in the 2022 assessment. The reason given: "limited EU evidence."

A moderate level, per the minutes, means mitigation measures still need to be put in place and sector awareness can be improved. The vulnerabilities are familiar ones to anyone who has watched this market:

• privacy and discretion in transactions
• market accessibility
• jurisdictional fragmentation

All three, the minutes note, facilitate illicit financial flows.

Which parts of the trade worry regulators most?

The secondary art market — resale rather than first-sale transactions — is identified as particularly exposed to criminal exploitation. Its threat level is also rated moderate (level 2).

Regulation has already moved. The Anti-Money Laundering Regulation (AMLR) broadened the scope of regulated entities to include operators dealing in "cultural goods" as defined by EU regulations, and introduced a €10,000 cap on large cash payments to curb anonymity. Ten thousand euros, it turns out, is where Brussels draws the line between a purchase and a paper trail.

Alongside the downgrade, DG FISMA put forward recommendations "aimed at mitigating risks and strengthening regulatory oversight" of the art trade. These include:

• continuous dialogue with stakeholders in the art and antiques markets
• awareness-raising campaigns
• targeted training programmes
• the development of guidance and codes of ethics to promote compliance and best practices

Dialogue, campaigns, training, codes of ethics. The sector has received gentler prescriptions.

How did the art market react?

Reactions split along predictable lines. The British Art and Design Association "welcomed the reassessment," according to the minutes. The International Association of Dealers in Ancient Art went further, challenging even the moderate rating and pointing to reports by the European Commission's Financial Intelligence Unit which found that only 0.3 percent of art and antiquities items in the EU have been connected to criminal cases.

Zero point three percent. The dealers' argument is arithmetic: a sector flagged as high-risk in 2022 has produced a vanishingly small share of criminal cases. Whether that figure reflects a clean market or thin enforcement is the question the SNRA will have to answer when it lands in 2026 — and one Brussels, with its new softer rating, has effectively answered in the market's favor.