Key Insights from TRACFIN’s 2026 Report on the Art sector
The art market’s structural features of high-value transactions, subjective pricing, cross-border flows, confidentiality, and frequent use of intermediaries, make it inherently exposed to money laundering and terrorist financing risks. Works of art and antiquities are easily transportable and storable, allowing them to be used as vehicles for concealing illicit funds or transferring value discreetly across jurisdictions.
Recognising these vulnerabilities, France has brought art market professionals firmly within its anti-money laundering and counter-terrorist financing (AML/CFT) framework. Galleries, art and antiquities dealers, auction houses, brokers, art investment advisers, and art storage and logistics operators are all subject to customer due diligence, transaction monitoring, and suspicious activity reporting obligations. Non-compliance can result in severe administrative and criminal sanctions.
TRACFIN’s January 2026 Focus report on the art sector provides a rare, detailed view of how illicit finance actually manifests in the art market, drawing on suspicious transaction reports received between 2021 and 2024. While the report is French in origin, its findings are highly relevant to the global art market.
A sharp rise in suspicious activity
In 2024, TRACFIN received 1,109 suspicious transaction reports linked to the art market, representing a 35% increase compared with 2023, and more than double the volume reported in 2021. The upward trend continued into 2025.
However, the source of these reports is striking. Banks and other financial institutions accounted for the vast majority of disclosures, with banks alone responsible for approximately 58% of art-related reports. By contrast, art market professionals themselves accounted for less than 1% of the reporting flow. Given the scale and value of the art market, TRACFIN considers this level of reporting by galleries and dealers to be disproportionately low and indicative of under-detection or under-reporting of risk.
From a criminal perspective, tax fraud is the most frequent underlying offence detected in art-related cases. Art transactions are commonly used to understate taxable income, conceal capital gains, misuse VAT regimes, or disguise donations and wealth transfers. Beyond tax evasion, TRACFIN identified recurring cases involving misuse of corporate assets, fraud and scams, organised money laundering, and, in more limited cases, terrorist financing through the trafficking of looted antiquities.
Core typologies identified
TRACFIN groups the principal risks in the art market into five broad categories:
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Tax fraud using art transactions, including undervaluation, offshore routing of sale proceeds, and disguised gifts or inheritance transfers.
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Abuse of corporate assets, where company funds are used to purchase art for the private benefit of directors or shareholders.
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Fraud and scams, including forged artworks, false certificates of authenticity, and fictitious art investment schemes.
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Money laundering through structured art transactions, often involving multiple intermediaries, shell companies, or cascading resale structures.
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Terrorist financing via antiquities, particularly where looted cultural property from conflict zones is trafficked into international markets.
Illustrative case patterns
The report highlights several recurring scenarios that should resonate with art professionals worldwide:
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Art sales used to disguise intergenerational wealth transfers, where the declared buyer or seller does not reflect the true economic reality and prices deviate materially from market value.
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Company-funded art purchases delivered to private residences, indicating possible misuse of corporate assets.
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Auction proceeds routed to undeclared offshore accounts, frequently in low-tax or high-secrecy jurisdictions.
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Fraudulent art investment opportunities, often involving high-risk jurisdictions, large cash withdrawals, forged documents, and promises of unrealistic returns.
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Cascade sales and artificial price inflation, using related entities to launder funds or create fictitious profits.
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Organised laundering schemes, where multiple shell companies with no link to the art market collectively acquire high-value works to obscure the origin of funds.
Key red flags for the art market
TRACFIN’s analysis translates into practical warning signs that art businesses, private clients, banks, and advisers should actively monitor:
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Payments made by third parties unrelated to the named buyer or seller.
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Requests to change invoices, ownership details, or payment instructions after a transaction.
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Art purchases inconsistent with a client’s profile or business activity.
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Use of shell companies, offshore vehicles, or opaque ownership structures.
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Significant discrepancies between valuation and transaction price.
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Rapid resale of artworks at substantially different prices without a clear commercial rationale.
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Large cash movements or unexplained international transfers, particularly involving high-risk jurisdictions.
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Incomplete or dubious provenance documentation, especially for antiquities.
These indicators do not prove wrongdoing but should trigger enhanced due diligence and, where appropriate, suspicious transaction reporting.
Global relevance and advisory perspective
Although TRACFIN’s report focuses on France, the risks it identifies are clearly global. The international nature of the art market means that similar schemes arise across major art hubs, free ports, and offshore storage facilities. Increasing regulatory scrutiny across Europe, the United States, and other jurisdictions confirms that the art sector is no longer viewed as peripheral to financial crime controls.
Rosemont International can advise art market participants, private collectors, family offices, and financial institutions on navigating these evolving AML/CFT obligations. The TRACFIN report provides a valuable benchmark for strengthening internal controls, improving transaction transparency, and aligning art-related structures with international compliance expectations.
As regulators continue to close gaps in the art market, proactive risk management is no longer optional. Effective due diligence, early identification of red flags, and informed advisory support are essential to protecting both the integrity of the art market and the interests of legitimate participants worldwide.
For more information, please contact office@rosemont-mc.com
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