2025 in Review — ArtAML: Tougher Sanctions Enforcement and AML Penalties in the UK Art Market

ArtAML's annual review noted that 2025 saw significantly tougher sanctions enforcement across the UK art market, with greater transparency around penalties, prosecutions, and disclosure notices issued by the Office of Financial Sanctions Implementation (OFSI). The review highlighted that HMRC and the NCA moved from issuing guidance to active enforcement, imposing penalties and opening high-profile investigations targeting art market participants.