Anti-money Laundering Regulatory Compliance by Private Sector Art Market Actors: Toward a Different Mode of KYC

With the adoption of the EU’s Fifth Anti-Money Laundering (AML) Directive, art market actors have been explicitly added to the list of obliged entities. This chapter is based on ongoing research which explores how regulatory changes have impacted art market actors, how they have worked to address them, and what kind of organizational thinking is necessary to do this effectively. Drawing on qualitative interviews with art market actors, and my practical experience on AML and sanctions compliance, this paper presents preliminary findings, focusing on the perceived nature and structure of the art market, and the implications of this perception to its role in the fight against money laundering. This chapter argues that the niche nature of the art market, made of dense relationships, does not prove fruitful to AML compliance, on the contrary, it is seen to ruin the very structure of the market. With a market this relational, AML regulation needs not only to be aware of these relationships, but also to use and tap into them to be effective.