High-value, subjectively priced and traded in a market with a long tradition of privacy, art and antiquities can move large sums between parties whose identities stay behind intermediaries — which is why the FATF devoted a dedicated 2023 report to the sector.
The rating above is indicative — it reflects inherent risk as assessed in the published frameworks, not a verdict on any business. Entire industries serve these sectors as business as usual; the rating your firm actually applies comes from its own business-wide risk assessment, where the sector factor combines with your customer base, controls and risk appetite.
The FATF's 2023 report on money laundering and terrorist financing in the art and antiquities market identifies the structural attractions: subjective valuation (a price can be almost anything a buyer will pay), a culture of discretion, routine use of third-party intermediaries and advisers, and storage options such as freeports that keep objects — and their owners — out of sight. It also documents terrorist groups monetising cultural objects looted from areas where they operate.
The EU has responded on both fronts: the Fifth Anti-Money Laundering Directive brought art-market participants into scope as obliged entities for transactions of EUR 10,000 or more (including via freeports), and Regulation (EU) 2019/880 imposes import controls on cultural goods entering the Union.
Art-market participants must apply customer due diligence on transactions at or above the EUR 10,000 threshold, identify the beneficial owner on both sides where they act for the transaction, scrutinise provenance and export documentation, and report suspicion. Sector risk combines with geography, the customer’s profile and the product to set the overall rating — and every client still needs sanctions, PEP and adverse-media screening on the parties themselves.
