15.07.2026 , General Art Law

Art Trade and Money Laundering

The art market has long been regarded as vulnerable to money laundering. Opaque price formation, high-value single transactions, an established culture of discretion, a dense network of intermediaries, and an international network of freeport storage facilities all favour the concealment of illicit assets. The regulatory responses differ significantly between Liechtenstein, Switzerland, and the European Union.

How closely the art trade and organised crime can be intertwined is illustrated by a case from Amsterdam. In the early hours of 07 December 2002, thieves stole two early works by Vincent van Gogh from the Van Gogh Museum in Amsterdam: "View of the Sea at Scheveningen" (1882) and "Congregation Leaving the Reformed Church in Nuenen" (1884–85). It was not until September 2016 that Italian financial police recovered the paintings during a raid against the Amato-Pagano Camorra clan, in a farmhouse in Castellammare di Stabia in the province of Campania.

The case illustrates why art dealers should regard the due diligence obligations under Art 5 of the Due Diligence Act (Sorgfaltspflichtgesetz, SPG) not as a formality but as a shield against criminal liability. The following article traces the key points and highlights where the legal position remains in flux ¹.

Liechtenstein: Art Trade Within the Scope of the SPG

Liechtenstein's legal position is largely based on the implementation of the EU anti-money laundering directives, namely Directive (EU) 2015/849 as amended by Directive (EU) 2018/843 (the "4th" and "5th AML Directives"), which must be incorporated into national law via the EEA Agreement; the 6th AML Directive (Directive (EU) 2024/1640) and the AMLR (Regulation (EU) 2024/1624) must be transposed into national law, or will become directly applicable in Liechtenstein, by 10 July 2027. Liechtenstein has expressly brought the art and antiques trade within the scope of its due diligence legislation. Anyone trading in works of art or acting as an intermediary in the art trade – including art galleries and auction houses – qualifies as a person subject to due diligence obligations under Art 3 Abs 1 lit u SPG (Due Diligence Act, LGBl 2009/047 as amended), provided the value of a transaction amounts to CHF 10,000 or more. In addition, Art 3 Abs 1 lit q SPG captures the professional trade in goods generally, where payment is made in cash or by means of a crypto-asset and the amount is CHF 10,000 or more (Art 5 Abs 2 lit e SPG) ². The threshold applies regardless of whether payment is made in a single transaction or in several linked transactions; splitting payments into smaller tranches ("smurfing") does not exclude the due diligence obligations. Going beyond the requirements of the AML Directives, Art 3 Abs 1 lit v SPG also captures, more generally, persons who professionally hold third-party assets in safekeeping or let premises and containers for the storage of valuables – thereby capturing, as a new category of persons subject to due diligence obligations, operators of customs and value-storage facilities as well as custodians of works of art outside freeports (LGBl 2020/305). Art dealers under lit u, traders in goods under lit q, and custodians under lit v are all reporting parties under Art 3 Abs 3 SPG: they must notify the FMA without delay of the commencement of their due-diligence-relevant activity and are thereafter subject to its risk-based supervision ³.

Art dealers are accordingly subject to the due diligence obligations set out in Art 5 et seq SPG: establishing and verifying the identity of the contracting party (Art 6 SPG), establishing and verifying the identity of the beneficial owner (Art 7 SPG), preparing a business profile that clarifies the source of funds and the source of wealth (Art 8 SPG), risk-adequate monitoring of the business relationship (Art 9 SPG), enhanced due diligence in cases of elevated risk (Art 11 SPG), and reporting to the Financial Intelligence Unit (Stabsstelle Financial Intelligence Unit, SFIU) where there are reasonable grounds to suspect money laundering, a predicate offence, or terrorist financing (Art 17 SPG) ⁴. These obligations are supplemented by those under the International Sanctions Act (Gesetz über die Durchsetzung internationaler Sanktionen, ISG, LGBl 2009/041 as amended), which requires screening against sanctions lists and checking for embargoes – in the art trade, this is particularly relevant for works connected with sanctioned persons or regimes.

Sector-specific guidance can be found in FMA Guidance 2018/7 on the general and sector-specific interpretation of due diligence law ⁵. This guidance has been revised several times since its issuance, most recently following the implementation of MiCAR; earlier versions are no longer in force. Accordingly, the version in force at the relevant time must always be consulted for specific queries. Breaches of the due diligence obligations constitute administrative offences (Art 30 et seq SPG); in the case of wilful breach, the person subject to due diligence obligations may also be liable to prosecution for money laundering under § 165 of the Criminal Code (Strafgesetzbuch, StGB, LGBl 1988/037 as amended) or for handling stolen goods under § 164 StGB. The ongoing full revision of the FIU Act (consultation draft, March 2026) will further adjust the institutional framework and will also standardise the designation of the SFIU ⁶.

Switzerland: Selective Cash Rules – and Direct Application of the CPTA in Liechtenstein

The FATF has identified the art and antiques market as a high-risk sector and has formulated minimum standards for capturing dealers ¹. Switzerland has so far implemented these requirements only selectively. The art trade is not generally subject to the Anti-Money Laundering Act (Geldwäschereigesetz, GwG, SR 955.0) as a financial intermediary. Since the 2016 revision, however, dealers – including art dealers – are subject to special due diligence obligations where they accept cash of more than CHF 100,000 in the course of a trading transaction (Art 8a GwG). They must identify the contracting party and the beneficial owner, document the transaction, maintain a due diligence file, and report to the Money Laundering Reporting Office Switzerland (MROS) where there are reasonable grounds for suspicion (Art 9 Abs 1bis GwG). Dealers are not subject to supervision by self-regulatory organisations (SROs); under Art 15 GwG, they are merely required to engage an auditor in respect of a cash transaction exceeding CHF 100,000 ⁷. The Federal Council's original proposal for an outright ban on such cash transactions was watered down by Parliament into the current identification-based solution ⁸.

This limitation to cash transactions has attracted considerable criticism. It is argued that the GwG obligations can be circumvented by splitting payments, by bank transfers routed through intermediary structures, or by avoiding cash altogether, and that neither the auction sector nor the logistics and storage sector is comprehensively covered ⁹. The gap is particularly visible where works are moved through freeports. In the "freeports" of Geneva, Luxembourg, Singapore, and Delaware, works of art and cultural property worth several billion are stored without the underlying ownership structures being readily apparent to outside authorities. Changes of ownership can occur multiple times within a freeport without the work being physically moved or customs duties and taxes falling due; the shift from a storage agreement to a silent transfer of ownership largely removes such transactions from customs and tax visibility, and – absent GwG coverage of the warehouse operators – from anti-money laundering supervision as well. Singapore has tightened its AML regime for the freeport at Changi Airport since 2019 and took further measures in 2024; in Switzerland, the debate on tighter regulation of freeports remains unresolved.

The Swiss Cultural Property Transfer Act (Kulturgütertransfergesetz, KGTG, SR 444.1) requires, under Art 16 KGTG, that dealers identify the person delivering the item and demonstrate the chain of dealers, thereby establishing a distinct due diligence obligation under cultural property law; in the field of anti-money laundering, however, these obligations apply only selectively and do not close the gaps in the GwG.

For the Liechtenstein art trade, the KGTG is not merely foreign law with indirect effect. Liechtenstein and Switzerland have formed a common customs territory since the Treaty of 29 March 1923 on the Accession of the Principality of Liechtenstein to the Swiss Customs Territory (Zollvertrag, ZV, LGBl 1923/24). On the basis of Art 4, 7, 9, and 10 ZV and the Act of 20 June 1996 on the Publication of Swiss Legal Provisions Applicable in Liechtenstein Pursuant to the Customs Treaty (LGBl 1996/122), the Government publishes, by periodic notice, the Swiss enactments applicable in Liechtenstein by virtue of the Customs Treaty; the KGTG, together with the Cultural Property Transfer Ordinance (Kulturgütertransferverordnung, KGTV, SR 444.11), forms part of this published list (Annex I). Its application is expressly confirmed at the domestic level by Art 1 Abs 3 lit d of the Cultural Property Act (Kulturgütergesetz, KGG, LGBl 2016/270), which leaves the Swiss legal provisions applicable under the Customs Treaty unaffected. The KGTG therefore applies directly to every import, export, and transit of cultural property through Liechtenstein territory – irrespective of whether the individual transaction otherwise has any connection with Switzerland. Excepted from this incorporation are, according to the published notice, only the provisions on the return of cultural property from Liechtenstein and international administrative and judicial assistance, for which Liechtenstein maintains its own regime under the KGG. The due diligence obligations under Art 16 KGTG accordingly apply to Liechtenstein art dealers directly by virtue of Liechtenstein's own enactment, and not merely as a reflex of a Swiss client relationship.

The circumvention of sanctions through art transactions following Russia's annexation of Crimea, and following the start of the war in Ukraine, prompted Motion 22.3104, submitted by National Councillor Jon Pult on 10 March 2022, entitled "No Circumvention of Sanctions: Bringing the Art Trade Within the Scope of the Anti-Money Laundering Act" ¹⁰. The motion called for the art trade and the auction sector to be brought fully within the scope of the GwG. The Federal Council recommended its rejection on 18 May 2022; the National Council nonetheless adopted the motion on 02 May 2023 by 111 votes to 80, and it has not yet been finally dealt with in the Council of States ¹⁰. In parallel, the Federal Council pursued a broader reform in its Dispatch of 22 May 2024 (BBl 2024 1316, item 24.046) on the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG), including a central register of beneficial owners; a general subjection of the art trade is not provided for therein. The Council of States' Legal Affairs Committee split the bill into two drafts in autumn 2024: Draft 1 on the transparency register and Draft 2 on due diligence obligations for advisers ¹¹. The Federal Chambers adopted Draft 1 on 26 September 2025; Draft 2 continues to be considered separately ¹¹.

European Union: Low-Threshold Coverage and the AMLR from 2027

The EU pursues a considerably stricter approach, and in doing so creates the very foundations that Liechtenstein implements via the EEA Agreement. The 5th Anti-Money Laundering Directive (Directive (EU) 2018/843, OJ L 156, 19 June 2018, p 43) expressly brought persons trading in works of art or acting as intermediaries in the art trade – including galleries, auction houses, and freeport warehouse keepers – within the circle of obliged entities. Identification and due diligence obligations apply from transactions, or linked chains of transactions, of EUR 10,000, regardless of whether payment is made in cash or otherwise. The threshold was thereby lowered compared with the previous rule (EUR 15,000 for cash payments) and extended to non-cash payments ¹².

With the 2024 AML package, the regulatory regime shifts further, as Regulation (EU) 2024/1624 (the AMLR, or "Single Rulebook", OJ L, 19 June 2024) becomes directly applicable in all Member States from 10 July 2027 and replaces the previous directive-based architecture. Dealers and intermediaries in art and cultural property are obliged entities where they trade in, or act as intermediaries for, cultural goods within the meaning of Annex I to Regulation (EC) No 116/2009 and the transaction value is at least EUR 10,000 (Art 3 No 3 lit i AMLR). The AMLR also provides for an EU-wide cash ceiling of EUR 10,000 for commercial transactions (Art 80 AMLR); stricter national rules with lower limits remain permissible. The package is accompanied by the establishment of the EU Anti-Money Laundering Authority (AMLA), based in Frankfurt am Main (Regulation (EU) 2024/1620), and by the 6th Anti-Money Laundering Directive (Directive (EU) 2024/1640), with a transposition deadline of 10 July 2027. For Liechtenstein, this means that these legal acts must be incorporated into national law under Art 102 of the Agreement on the European Economic Area (EEA Agreement, LGBl 1995/068); the incorporation procedure is led by the FMA in coordination with the EEA Coordination Unit (Office of Foreign Affairs) ¹³.

The Latchford Case: Trust Structures and Provenance Fraud

The extent to which the illicit trade in art and antiquities can be interwoven with money laundering and the concealment of assets through offshore structures – and how the gaps in the freeport and trust landscape are exploited in practice – is illustrated by the case of the British art dealer Douglas Latchford. The US Attorney's Office for the Southern District of New York indicted him on 27 November 2019 for wire fraud, smuggling, and conspiracy in connection with stolen Cambodian antiquities (United States v Latchford, 19 Cr 748 (AT), SDNY, indictment of 27 November 2019); following Latchford's death on 02 August 2020, the criminal proceedings were discontinued in September 2020 ¹⁴. As early as 2011, US proceedings concerning a "Koh Ker statue" consigned to Sotheby's had already provided initial indications of the systematic pattern involved.

The Pandora Papers, published in October 2021, revealed that Latchford held funds and antiquities through trusts established in Jersey, and sold works to renowned museums through these structures ¹⁵. Several leading institutions, including the Metropolitan Museum of Art and the Denver Art Museum, subsequently returned pieces from the Latchford collection to Cambodia or withdrew them from their holdings for review. In June 2023, the Latchford estate further agreed to pay USD 12 million and to surrender a Vietnamese bronze statue (a 7th-century Durga statue) to the US authorities ¹⁴. The case is emblematic of structural weaknesses: falsified provenance documents, offshore trusts used to shield assets, and the involvement of established auction houses and museums without adequate due diligence.

The Stolen Van Goghs: Drug Cartels, the Camorra, and the Return to Amsterdam

The theft outlined in the introduction concerned "View of the Sea at Scheveningen" (1882), the only work from Van Gogh's Hague period in the museum's collection, and "Congregation Leaving the Reformed Church in Nuenen" (1884–85), depicting the church where Van Gogh's father served as pastor. The thieves climbed onto the roof via a ladder in the early hours of 07 December 2002 and broke a window ¹⁶.

The paintings remained missing for fourteen years. It was not until September 2016 that officers of the Guardia di Finanza recovered the works during a large-scale raid against the Camorra, at a farmhouse in Castellammare di Stabia, wrapped in cotton cloths and hidden behind a plasterboard wall in a cavity next to the kitchen. The raid targeted the Amato-Pagano clan; assets worth around EUR 20 million were seized, including villas, apartments, and a light aircraft ¹⁷. The paintings were first exhibited at the Museo di Capodimonte in Naples in February 2017 and handed over to the Van Gogh Museum in Amsterdam on 21 March 2017 ¹⁸.

The alleged buyer of the paintings, Raffaele Imperiale, born on 24 October 1974 in Castellammare di Stabia, had already fled to Dubai in 2016 ¹⁷. Italian investigators identified him as heading an international cocaine trafficking network which, at its peak, imported cocaine directly from Colombian cartels in significant quantities and distributed it across large parts of Europe ¹⁹. Imperiale had featured on Italy's list of most dangerous fugitives since January 2016. On 04 August 2021, Dubai police arrested him in a joint operation with Interpol, Europol, and Italian authorities ¹⁹.

Imperiale's hideout was no accident: the United Arab Emirates was, until a few years ago, regarded as a safe haven for persons subject to international arrest warrants, as no bilateral extradition treaty existed with a number of states, including Italy. It was only the extradition treaty between Italy and the United Arab Emirates, signed in Abu Dhabi on 16 September 2015 and entering into force upon ratification by both states (Trattato di estradizione, ratified by Law No 65 of 26 April 2017, Official Gazette No 108 of 11 May 2017), that created the legal basis for surrender; Imperiale was ultimately extradited to Italy in March 2022 ²⁰. In an interview with Il Mattino given before his arrest, Imperiale described his acquisition of the works as an act of art appreciation, claiming to have bought the paintings directly from the thief because he was a passionate art lover ²⁰. Investigators and the art journalist Martin Bailey take a different view, noting that works of art typically serve as collateral in international drug trafficking: they are pledged against forthcoming cocaine shipments from South America until street sales generate the funds for payment ²⁰.

Organised Crime and Sanctions Evasion

The Imperiale case is not an isolated one. Organised crime exploits the gaps described above systematically and in varying configurations. Studies concerning Italy have for years shown the involvement of the Camorra, the 'Ndrangheta, and Cosa Nostra in both the looting and the movement of archaeological finds, with crime scenes in southern Italy and distribution channels via auction venues in Western Europe and North America ²¹. Whereas the Latchford case illustrates the interplay of smuggling, provenance fraud, and offshore trusts, the Imperiale case illustrates the function of art as collateral in international cocaine trafficking – its use as a pledge between cartels and European drug distribution networks. A comparable pattern can be observed in Italy's most prominent unsolved art theft. Caravaggio's "Nativity with Saints Lawrence and Francis" (1600) was stolen from the Oratorio di San Lorenzo in Palermo on the night of 17 to 18 October 1969 and remains missing to this day; investigations by the Italian anti-mafia authorities proceed on the basis that the work was passed between mafia families within Cosa Nostra as a form of collateral ²¹.

Findings of a US Senate subcommittee further show that sanctions evasion has also been carried out by means of the art trade. A 2020 report set out in detail how Russian oligarchs, immediately after being listed in 2014, acquired works of art worth several million US dollars through intermediary companies ²². In February 2023, the FATF published its first comprehensive report on money laundering and terrorist financing in the art and antiquities market, together with a catalogue of risk indicators: an unusual preference for anonymity, third parties with no discernible economic interest, abrupt price increases, invoicing routed through other jurisdictions, payment in several smaller tranches, provenance gaps spanning periods of conflict, and the use of shell companies ¹. This FATF report is also relevant to the Swiss debate on extending GwG coverage of the art trade; the FATF notes at the same time that many states lack sufficient investigative resources and specialist expertise, which hampers cross-border investigations.

What This Means in Practice

For art dealers active in Liechtenstein, the SPG applies with clear identification and reporting obligations from a transaction value of CHF 10,000. Anyone dealing with clients connected to the Swiss or European market must also observe differing thresholds: CHF 10,000 (Liechtenstein, regardless of the method of payment for art dealers under Art 3 Abs 1 lit u SPG; CHF 10,000 for cash or crypto-asset payments under Art 3 Abs 1 lit q SPG), CHF 100,000 (Switzerland, cash payments), and EUR 10,000 (EU, regardless of the method of payment; directly under the AMLR from 10 July 2027). In cross-border transactions, the strictest applicable rule generally governs, supplemented by the obligations under the ISG and, in the field of cultural property, by the Hague Convention for the Protection of Cultural Property and the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property.

For every import, export, or transit of cultural property through Liechtenstein territory, Art 16 KGTG must also be observed, as it applies directly in Liechtenstein by virtue of the Customs Treaty: the dealer must identify the person delivering the item and demonstrate the chain of dealers. This due diligence obligation under cultural property law exists independently of the anti-money laundering threshold under Art 8a GwG and independently of whether the transaction has any separate connection with Switzerland.

In practice, a systematic provenance check is recommended, comprising at minimum: an unbroken chain of ownership since 1970 (the reference date of the 1970 UNESCO Convention), or since 1933 for works with Nazi-era relevance (the reference date of the 1998 Washington Declaration on works confiscated by the National Socialists); a check against the relevant databases (the Art Loss Register, artloss.com; the Interpol database of stolen works of art, interpol.int/de/Verbrechen/Kulturgut-und-Werke/Werke-suchen; the Lost Art database of the German Lost Art Foundation, lostart.de); a check of any export permits from the country of origin; and a plausibility assessment of the purchase price history.

The case of the stolen Van Goghs shows that even works stolen from world-famous museums can circulate unseen within criminal structures for several decades before resurfacing; a provenance check limited to the immediately preceding seller is therefore insufficient. Particular caution is warranted for works from crisis or conflict regions, for consigned items with incomplete provenance, for transactions initiated through offshore structures or freeports, and for buyers who place an unusual emphasis on anonymity or act through nominees with no discernible economic rationale. Switzerland's second national risk assessment (KGGT, October 2021) and Austria's national risk assessment (Federal Ministry of Finance, May 2025) both continue to classify the art and antiques trade as a high-risk sector ²³.

The authors are available for further advice on due diligence issues in the art trade, as well as on structuring acquisitions, sales, loans, and restitution transactions.

 

The Authors:

MMag. Thomas Plattner und MA HSG Fabian Jenny

 

Sources

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