The November 2026 issue of the Journal of the CNE (Compagnie nationale des experts) features an article by Alexis Fournol on anti-money laundering and counter-terrorist financing obligations in the French art market.
Entitled “AML/CFT: an imperative necessity”, the article examines the increasing compliance requirements applicable to art dealers, antique dealers and professionals acting as intermediaries in art transactions.
2026 marks a significant development in the enforcement of French AML/CFT rules. The first issue of Focus Tracfin devoted to the art market, together with recent decisions of the French National Sanctions Commission (Commission nationale des sanctions – CNS), confirms that compliance is no longer assessed solely by reference to the existence of written policies. Authorities increasingly examine whether risk assessments, internal procedures and customer due diligence measures are effectively implemented in practice.
The article also addresses an important issue for art experts: when does an expert become subject to AML/CFT obligations? Pure expertise, consisting in examining an artwork and expressing an opinion on its authenticity, attribution, condition or value without taking part in its sale or acquisition, does not in itself trigger the relevant AML/CFT regime. The position may be different where the same professional also acts as a dealer, buyer, seller or intermediary in a transaction.
The contribution also considers the practical steps expected from art-market professionals, including customer identification, beneficial ownership checks, risk mapping, enhanced due diligence where appropriate, proper record-keeping and periodic reviews of the compliance framework.
The article appears in both French and English in issue No. 27 of the CNE Journal.
This publication reflects Fournol & Associés’ AML/CFT practice for art-market professionals, including compliance programmes, preparation for regulatory inspections and representation in sanction proceedings in France.
