Analysis · Anti-money laundering — EU Regulation 2024/1620

AMLA & the art market — European supervision 2026

The AMLA (Anti-Money Laundering Authority), operational since 1 July 2025 in Frankfurt under EU Regulation 2024/1620, harmonises anti-money-laundering supervision across the EU. For the art market, the EUR 10,000 threshold triggers AML/CFT obligations for dealers, galleries and intermediaries: enhanced customer due diligence, provenance documentation, identification of the beneficial owner. Payments cannot be artificially split to circumvent this threshold.

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Analysis by Jonathan Bensaid · Tax lawyer · Paris & Geneva · 27 March 2026
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The essentials in 30 seconds

The AMLA (Anti-Money Laundering Authority), created by EU Regulation 2024/1620, became operational on 1 July 2025 in Frankfurt. Although its direct supervision initially targets only certain financial institutions by 2028, its effects reach the art market through regulatory harmonisation and the tightening of compliance required of Member States.

The EUR 10,000 threshold triggers AML/CFT obligations (the fight against money laundering and terrorist financing) for art dealers, galleries and intermediaries. Application of enhanced due diligence on the customer, complete documentation of the provenance of the work of art, identification of the beneficial owner. The artificial splitting of payments to circumvent this threshold is expressly prohibited.

In 2023, the FATF identified the structural vulnerabilities of the art market: incomplete provenance chains, opacity of private sales, multiple intermediaries, cross-border circulation. The regulatory response aims at documentary reconstruction, the identification of the beneficial owner and the traceability of transactions.

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AMLA, the EUR 10K threshold, market vulnerabilities and FATF standards

01

1. AMLA — creation and competence

The European anti-money-laundering supervisory authority, based in Frankfurt, operational since July 2025.

  • EU Regulation 2024/1620 — legal basis
  • Direct supervision initially of certain financial institutions (pan-European banks) by 2028
  • Indirect coordination of national supervisors for the other sectors (including the art market)
  • Power of instruction and of direct administrative fine
  • Guiding principle — harmonisation of AML/CFT supervisory practices across the EU
02

2. EUR 10,000 threshold — AML/CFT trigger

Any transaction on a work of art of EUR 10K or more triggers the due-diligence obligations.

  • Enhanced customer due diligence — identity document, proof of address, transaction profile
  • Documentation of the provenance of the work — complete chain of ownership
  • Identification of the ultimate beneficial owner (UBO) where the purchase is made through a company or a trust
  • Assessment of the money-laundering risk according to the customer profile, country and nature of the work
  • Artificial splitting of payments to stay below the threshold = expressly prohibited conduct
03

3. Vulnerabilities identified by the FATF

The FATF 2023 report identified 4 structural vulnerabilities of the art market.

  • Incomplete provenance chains — works without a documented history
  • Opacity of private sales — over-the-counter transactions with no public record
  • Multiple intermediaries — galleries, brokers, consultants, advisers
  • Cross-border circulation — facilitated by free ports and free zones
04

4. Regulatory response — 3 axes

The AMLA and the FATF standards converge on three operational priorities.

  • Documentary reconstruction — each work must have a detailed provenance file
  • Identification of the beneficial owner — who really benefits from the transaction
  • Traceability of transactions — means of payment, accounts used, cross-border movements
  • Convergence with DAC8 / CRS — tax transparency and anti-money laundering aligned
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Operational implications — collectors, professionals, free ports

Three profiles, three different readings of the new obligations.

The AMLA does not yet have direct power over the art market, but its effects are already tangible

Although direct AMLA supervision initially targets financial institutions, the standards it imposes spread de facto across the art market through the national supervisors (Tracfin in France, the Money Laundering Reporting Office in Switzerland, etc.). Market participants must adapt now.

Three profiles — three readings

For collectors

Complete provenance files, certificates of authenticity and transparent ownership structures become compliance assets, not optional extras. For a collection above EUR 1M, the documentation of each work must be up to date before any operation (sale, gift, dation in payment (payment in kind), transfer).

For professionals (galleries, advisers, dealers)

Written procedures, staff training and documented risk assessments become essential governance requirements. Beyond the EUR 10K threshold, each transaction must be traced and the customer identified beyond the mere presentation of an identity document.

For free ports and Switzerland

International transparency reduces the usefulness of discretion based on storage in a free zone. The documentation of movements and the clarity of the beneficial owner remain central, including for works stored in the free port of Geneva, Singapore, Delaware, etc.

Interaction with French law

In France, the AML/CFT obligations of the art market are governed by the Monetary and Financial Code (art. L.561-2 et seq.). Tracfin remains the national authority for supervision and for receiving suspicious-transaction reports. The AMLA reinforces the framework through European convergence, without replacing Tracfin for the art market (at this stage).

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Lead counsel — Jonathan Bensaid

Jonathan Bensaid, founding lawyer of the firm, admitted to the Paris & Geneva Bars, advises collectors, galleries, advisers and family offices on AML/CFT compliance, the audit of provenance chains, the structuring of cross-border transactions, and the defence in the event of a Tracfin suspicion or an AMLA enquiry.

  • EU Regulation 2024/1620 (AMLA)
  • Monetary and Financial Code art. L.561-2
  • FATF
  • Tracfin
  • Free ports
  • Paris & Geneva Bars
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Q&A — questions from art-market participants

Does the AMLA directly supervise galleries and art dealers?

No, not yet. Direct AMLA supervision initially targets certain financial institutions (pan-European banks) by 2028. For the art market, supervision remains ensured by the national authorities (Tracfin in France, the MLRO in Switzerland, etc.). But the AMLA harmonises the standards and practices of these authorities, hence a general intensification of controls.

Does the EUR 10,000 threshold apply to each transaction or to an annual total?

The EUR 10,000 threshold applies to each transaction or to a set of linked payments (artificial splitting is prohibited). If a customer buys 5 works at EUR 3,000 each in the same session, the operation is treated as a single transaction of EUR 15,000, triggering the AML/CFT obligations.

Which documents must I collect for a sale above EUR 10K?

The customer's identity document (passport or national ID card), a recent proof of address, a declaration on the wealth profile and the origin of the funds, identification of the beneficial owner where the purchase is made through a company or a trust, the provenance file of the work (complete chain of ownership, certificates of authenticity). The documents must be kept for at least 5 years after the end of the business relationship.

Do works stored in a free port escape the AMLA obligations?

No. Free ports are now at the heart of the concerns of the FATF and the AMLA. Any operation involving a movement of a work to or from a free port triggers the standard due-diligence obligations (identification, provenance, beneficial owner). Switzerland has reinforced its controls over the Geneva free port, and Singapore has done the same. Discretion based on storage in a free zone no longer offers legal protection.

What should I do if I detect a suspicious operation from a customer?

A mandatory suspicious-transaction report must be filed with Tracfin (in France), without informing the customer (prohibition of tipping-off). The report form is available on the Tracfin website. The reporting deadline is immediate as soon as the suspicion is established. Failure to report is subject to criminal sanction (up to 5 years' imprisonment and a EUR 375K fine). A systematic recommendation: have the characterisation of the suspicion validated by a lawyer before reporting.

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Written by

Me Jonathan Bensaid, avocat fiscaliste, fondateur du cabinet Bensaid Avocats, inscrit aux Barreaux de Paris & Genève.

© BENSAID Avocats — The information published on this site does not constitute legal advice. Sources: EU Regulation 2024/1620 (creation of the AMLA); EU Directive 2024/1640 (6th anti-money-laundering directive); EU Regulation 2024/1624 (AML/CTF package); French Monetary and Financial Code art. L.561-2 et seq.; FATF 2023 report on the vulnerabilities of the art market; Tracfin (French authority). Editorial update: 27 March 2026.