Anti-Money Laundering 101 for Australia’s Art Market Professionals
The global spotlight on financial crime in the art world is finally catching up in Australia, and the 2026 anti-money laundering reforms will be a defining shift. In this article, we unpack the new obligations, the risks, and why early preparation is becoming a hallmark of best-practice for art business.
When an art dealer in the UK was sentenced to prison in June this year for failing to comply with disclosure requirements under the UK’s terrorism financing laws, it sent ripples across the global art world. The prosecution of Oghenochuko Ojiri of Ojiri Gallery (also a former BBC Bargain Hunt show art expert), who sold £140,000 worth of art to a US-sanctioned individual, was the first of its kind. The case is a stark reminder that art market professionals are no longer beyond the reach of financial crime regulators.
Australia’s art market is now entering that same conversation, cautiously but with growing clarity.
What is anti-money laundering (AML) regulation and why should art professionals care?
AML regulation aims to stop legitimate markets from becoming conduits for proceeds of crime and terrorism financing. The art market’s combination of high-value assets, portability and private modes of sale on both the primary and secondary markets makes it especially exposed to these risks.
Although Australia introduced AML and counter-terrorism financing laws in 2006, they were directed mainly at financial institutions such as banks and casinos. But until now, the art market has sat outside this framework.
That is about to change.
What’s changing under the 2026 reforms?
From 1 July 2026, Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No.1) (AML/CTF Rules) will cover new categories of ‘designated services’. Businesses who provide ‘designated services’ are required to identify and verify their clients, monitor transactions, report suspicious activity to AUSTRAC (Australia’s AML/CTF regulator) and keep comprehensive records.
This next phase will extend obligations to:
dealers in precious metals and stones (from 1 July 2026)
professional service providers such as consultants and advisors who hold or manage client funds (for example, those who handle client money such as sale proceeds or purchase funds, whether that’s through escrow, a trust account or other arrangement where you hold funds on their behalf) (from 1 July 2026)
virtual asset service providers, including those with custody of customers’ NFTs and other digital assets (from 31 March 2026)
Will art market professionals be affected?
While the legislation does not explicitly mention “art dealers”, many art market professionals will fall within its scope if they hold or manage client funds or have custody of their clients’ virtual assets.
These include:
commercial galleries and dealers, including those who facilitating transactions using cryptocurrency
auction houses
art advisors and consultants
collectors or family offices
NFT and digital art platforms providing virtual asset services like custodial services and performing transfers of value using digital tokens
The trigger will generally be transactions of AUD $10,000 or more in physical currency or virtual assets (or a combination of both).
What will you be required to do?
If your business provides a ‘designated service’ under the AML/CTF Act, you will be subject to several obligations regulated by AUSTRAC. These include:
Register with AUSTRAC – all reporting entities must enrol before commencing designated services.
Develop an AML/CTF program – this may include, for example, an internal policy outlining how you identify, manage and mitigate money laundering and terrorism financing risks.
Conduct customer due diligence (CDD) – verifying certain information about clients and beneficial owners before providing them with designated services. Depending on the level of risk in a particular scenario, simplified to enhanced CDD options may be required.
Report transactions above the threshold and suspicious activities – including physical currency transactions of $10,000 or more and matters that raise red flags.
Maintain records – all due diligence, transaction and compliance records must be kept for at least seven years.
What are the consequences of non-compliance?
For those providing ‘designated services’, non-compliance with the AML/CTF Act and Rules can lead to enforcement actions by AUSTRAC, such as civil penalty orders, enforceable undertakings, infringement notices, remedial directions and the appointment of external auditors to review compliance.
Beyond the legal consequences, the reputational damage to a gallery, dealer, or digital assets platform caught in a money-laundering investigation can be profound and lasting.
What practical steps should art professionals in Australia take now?
With the reforms due to commence in March and July 2026, now is the time for art businesses to get ahead. Things you can do include:
Mapping your risk – identify where your business handles client funds or high-value assets.
Reviewing client onboarding – ensure your processes capture identity verification and beneficial ownership details.
Developing internal policies – assign responsibility for AML compliance and create a proportionate risk-management plan.
Seeking specialist advice – a tailored legal review can clarify whether your business provides a “designated service” under the AML/CTF Act.
Educating your team – awareness training helps staff recognise suspicious transactions and protect your business.
Looking Ahead
The coming years will mark a turning point for Australia’s art market. AML/CTF compliance will become part of best practice alongside robust contracts, privacy law compliance, provenance due diligence, insurance and other risk-mitigation measures.
As seen in the Ojiri case, even well-intentioned professionals can face serious consequences for ignoring red flags. The key is to be aware, prepared and proactive in your approach to compliance.
At Guest Work Agency we advise across the spectrum of art and luxury collectibles, helping clients understand and implement AML frameworks that are practical, proportionate and aligned with their business models.
If you’re unsure whether the upcoming reforms will apply to you, or what steps to take, now is the time to start the conversation. Get in touch with us.
Guest Work Agency
Providing innovative legal solutions for art and collectibles.
The contents of this article are of a general nature only. They are not and should not be used as legal advice.