EU Looking to Downgrade Money Laundering Risk in Art and Antiquities Trade

The European Commission, the executive branch of the European Union, is planning to downgrade its assessment of the money laundering and terrorist financing threat posed by the art trade, the Financial Times reports.

While a Commission spokesperson told the FT that the risk assessment has not yet been finalized, 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.

At that meeting, the Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA), which is responsible for EU banking and finance policy, presented key findings from its upcoming 2026 Supranational Risk Assessment (SNRA) on money laundering and terrorist financing. The minutes say the report will be published in 2026. The new assessment rates the threat linked to works of art and antiques as “moderate” (level 2), a downgrade from the previous assessment in 2022, which rated it as “high,” citing “limited EU evidence.”

Per the minutes: A moderate level signifies that mitigation measures need to be put in place and that sector awareness can be improved. However, vulnerabilities remain and include privacy and discretion in transactions, market accessibility, and jurisdictional fragmentation, all of which facilitate illicit financial flows. In response, the Anti-Money Laundering Regulation (AMLR) broadened the scope of regulated entities to include operators dealing in “cultural goods” as defined by EU regulations, while also introducing a €10,000 cap on large cash payments to curb anonymity. On the money laundering front, the SNRA identifies the secondary art market as particularly exposed to criminal exploitation, with the threat level also assessed as moderate (level 2).

Alongside the downgrade, DG FISMA put forward a series of 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, alongside awareness-raising campaigns, targeted training programmes, and the development of guidance and codes of ethics to promote compliance and best practices.”

The British Art and Design Association, according to the minutes, “welcomed the reassessment,” while the antiquities-focused industry group, the International Association of Dealers in Ancient Art, challenged even the moderate risk assesement, 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.