Vintro Pro
NL · FR · EN
Vintro Pro
NL · FR · EN
From £10,000 in the UK, and €10,000 across the Channel, duties apply that do not exist below: identify the customer, keep records for years, report a suspicion. Every rule below comes from the legislation itself — because three of the four governments publish something other than their own law.
Written by Griet Coussement, founder of Vintro Pro and Vintiques Export
Two amounts, and they have nothing to do with each other.
Anti-money laundering rules touch the art and antiques trade in two places, and those two are constantly confused. 10,000 decides whether you are regulated: from there you must know who your customer is, and be able to show it years later: ten years in Belgium (article 60), five in the Netherlands (article 33(3) Wwft). 3,000 is something else entirely — the ceiling above which an amount may no longer be paid in cash, and on the continent it applies always, even on a 4,000 euro piece that asks nothing else of you.
This page sets both thresholds side by side for the United Kingdom, Belgium, the Netherlands and France. Every rule comes from the legislation itself, not from a guidance page — and that turned out to matter, because the two disagree. What you record for every piece anyway is on the stock list page.
While those two run together, you think a 6,000 sale falls “outside the rules”. That is true for one and false for the other.
One 6,000 sale, two answers
Identify the customer?
No 6,000 is below the 10,000 threshold.All in cash?
Not on the continent Belgium allows up to €3,000 in notes, the Netherlands less than €3,000, France €1,000.The UK has no cash cap. A suspicion is always reported, whatever the amount.
Until recently the British threshold was expressed in euros, in the British regulation itself. Not any more: since 30 June 2026 regulation 14 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 carries £10,000, substituted by The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (S.I. 2026/621), regs. 1(2) and 9.
The gov.uk guidance page Money laundering supervision for art market participants was last updated on 6 August 2024 and still says “10,000 euros or more”. Two government sources from the same country, two amounts — and the regulation wins.
Why it matters in practice: at roughly £0.85 to the euro, £10,000 is about €11,800. A sale of €10,500 therefore no longer reaches the UK threshold, where under the old wording it did. Count in the currency the rule is written in, not the one in your till.
A €10,500 sale in the UK
The line is the threshold. Worked out at roughly £0.85 to the euro.
The number is 10,000 everywhere. The currency is not.
pounds, not euros — reg. 14 MLR 2017, amended 30-06-2026
work of art: any age; other piece: “more than fifty years old” — art. 5, §1, 31°/1
works of art, no age test — art. 1a(4)(k) Wwft
“égal ou supérieur” — art. L561-2, 10° CMF
This limit has nothing to do with the previous one, and the gap between Belgium and the Netherlands comes down to a single word.
but from £10,000 in cash: high value dealer
art. 67(2) — exactly 3,000 is still allowed
art. 1f Wwft — exactly 3,000 is already too much
art. D112-3 CMF — €15,000 for a non-resident
Enter the sale and read both answers: are you regulated, and may the cash part be paid in cash. The currency follows the country — the UK counts in pounds.
Four countries, four legal texts. These are the sentences themselves, not a summary of them.
“a firm or sole practitioner who… by way of business trades in, or acts as an intermediary in the sale or purchase of, works of art and the value of the transaction, or a series of linked transactions, amounts to £10,000 or more”. And 14(1)(a), the high value dealer: “a firm or sole trader who by way of business trades in goods (including an auctioneer dealing in goods), when the trader makes or receives, in respect of any transaction, a payment or payments in cash of at least £10,000 in total”.
Natural or legal persons who buy, sell or act as an intermediary in the trade of works of art or movable goods “van meer dan vijftig jaar oud”, where the sale price of one or a set of these works or goods “gelijk is aan of hoger is dan 10 000 euro”, and who are registered with the FPS Economy. The provision adds: “De tussenpersonen omvatten kunstgalerieën, veilinghuizen en organisatoren van beurzen en salons”. The fifty years belongs to the movable goods: article 4(24/1) defines a work of art as the original work of art within article XI.175(1), second and third paragraphs, of the Code of Economic Law — with no age.
Persons or companies acting professionally as buyer or seller of works of art, “voor zover betaling van deze kunstvoorwerpen plaatsvindt voor een bedrag van € 10.000 of meer, ongeacht of de transactie plaatsvindt in een handeling of door middel van meer handelingen waartussen een verband bestaat”.
“Les personnes qui négocient des œuvres d’art et des antiquités ou agissent en qualité d’intermédiaires dans le commerce des œuvres d’art et d’antiquités, y compris lorsque celui-ci est réalisé par des galeries d’art, lorsque la valeur de la transaction ou d’une série de transactions liées est d’un montant égal ou supérieur à 10 000 euros”.
One sentence in the Belgian law is almost never quoted, and it changes the sum entirely for anyone selling at auction. Article 5, §1, 31°/1, third sub-paragraph:
“Wanneer de tussenpersoon een veilinghuis is, is de in het eerste lid bedoelde verkoopprijs de maximumschatting door het veilinghuis.” — where the intermediary is an auction house, the sale price referred to is the auction house’s maximum estimate.
The threshold is therefore measured not against what the lot fetches but against the top of your own estimate — the one you print in the catalogue weeks before the room fills. A lot estimated at €8,000–11,000 that sells for €6,500 sits above the threshold for the purposes of that provision.
A lot estimated at €8,000–11,000
Belgian rule for auction houses: the top of your estimate counts, not the hammer price.
For specialised warehouses the price falls away altogether: 31°/2 names owners and operators of warehouses offering a storage service specifically for works or goods over fifty years old, with no amount at all. The UK equivalent is the freeport operator in regulation 14(1)(d)(ii).
At exactly €3,000 Belgium and the Netherlands part company, and it comes down to two words.
No payment or gift in cash may be made or received “voor meer dan 3 000 euro”. A cash payment of exactly €3,000 therefore remains allowed.
It is forbidden to make or accept payment for goods in cash “voor een bedrag van € 3.000 of meer”. Exactly €3,000 is therefore already too much.
A small gap, and yet it is precisely the figure people round to. The calculator above accounts for it: enter 3000 and switch countries.
For gold, silver, platinum and palladium, Belgium goes lower. Article 67(2), second paragraph, 2° says that payment for “goederen die edele stoffen bevatten” (goods containing precious materials — “goud, platina, zilver, palladium” under §1, 2°) “a) [mag] niet in contanten worden verricht of ontvangen, wanneer noch de verkoper, noch de koper een consument is; b) niet in contanten worden verricht of ontvangen voor een bedrag van meer dan 500 euro wanneer de verkoper een consument is en de koper geen consument”. So between two traders not a single euro in cash, and when you buy from a private person no more than €500 — and you identify that seller. When you sell to a consumer yourself, the ordinary €3,000 applies. Excluded are precious materials present “slechts in kleine hoeveelheid en enkel omwille van hun noodzakelijke fysische eigenschappen” (only in a small quantity and only for their necessary physical properties), and a public sale under the supervision of a bailiff. Checked in Justel on 31 October 2026.
Anyone reading a guide or blog from before this year still finds a €20,000 objective reporting threshold there: any transaction in vehicles, works of art, antiques, precious stones or jewellery paid wholly or partly in cash for €20,000 or more had to be reported — with nothing left to judge.
That indicator was deleted from the annex to the Uitvoeringsbesluit Wwft 2018 by the decree of 7 April 2026, Staatsblad 2026, 99, in force on 30 April 2026. FIU-Nederland still applies it to reports with a transaction date up to and including 31 December 2025. The reason is the article 1f ban: a €20,000 cash transaction can no longer lawfully exist.
What did not go with it: the subjective indicator. A transaction you have reason to believe may be related to money laundering stays reportable — cash or not, whatever the amount.
The duties above ask three things per piece: what it cost and when, who it was sold to, and how it was paid for. The first two belong in your stock records anyway — see what belongs in your stock list. The third is the only one that genuinely gets added, and only above the threshold.
Where it goes wrong is the link. Years later you must still be able to show who bought that particular piece. A sales slip in a box and a stock list in another file rarely survive that long together. An invoice attached to the piece itself does.
Since 30 June 2026 regulation 14 reads £10,000. The gov.uk guidance page still says “euros”, but the regulation is what binds you.
“It is only 6,000, so the rules do not apply.” For the identification duty that is right. For the continental cash limit it is not.
Two invoices of 6,000 for the same set form a series of linked transactions. All four texts name that series explicitly.
Seven years for the books, ten years for these records in Belgium (article 60). Throw it all out together after seven and you throw out too early.
How long you keep it in Belgium
So do not put them on the same pile.
This is an explanation of your administration, not legal advice. Whether your business is regulated and what exactly that requires is something to check with your accountant or with the supervisor itself.
From GBP 10,000 in the United Kingdom, and from EUR 10,000 in Belgium and France. In the Netherlands the EUR 10,000 only applies to works of art (article 1a(4)(k) Wwft); for antiques that are not works of art, only the cash ban from EUR 3,000 applies there (articles 1a(1) and 1f). Belgium adds a second condition for pieces that are not works of art: article 5(1)(31/1) of the law of 18 September 2017 covers works of art OR movable goods more than fifty years old. The fifty years belongs to the movable goods. A work of art counts at any age: article 4(24/1) defines it as the original work of art, with no age. A 12,000 euro painting that is thirty years old is therefore covered in Belgium. A 12,000 euro cabinet that is thirty years old is not. The amount counts per transaction or per series of transactions that appear to be linked: splitting a sale does not help.
Not any more. It did, in regulation 14 of the Money Laundering Regulations 2017, and the gov.uk guidance page still says so: 10,000 euros or more. But the regulation itself was amended on 30 June 2026 by S.I. 2026/621 and now reads GBP 10,000. Anyone working from the euro figure has been using the wrong amount since that date.
No, and this is the confusion that goes wrong most often. The 10,000 decides whether you are regulated. The cash limit is entirely separate and sits far lower: article 67(2) of the Belgian law bans cash for MORE THAN 3,000 euros, article 1f of the Dutch Wwft bans cash from 3,000 euros OR MORE, and article D112-3 of the French Code monetaire et financier sets 1,000 euros for a French tax resident. Exactly 3,000 euros is therefore still allowed in Belgium and no longer in the Netherlands. The UK has no general cap at all.
In Belgium ten years, and that is article 60 of the law of 18 September 2017 -- not article 57, which is widely cited by mistake. Identification data ten years from the end of the business relationship or from the date of an occasional transaction, and transaction records ten years from execution. That is longer than the seven years your bookkeeping asks for, so do not put them on the same pile. In the Netherlands it is five years (article 33(3) Wwft).
You report it, whatever the amount. Article 47(1)(1) of the Belgian law uses exactly those words. The duty hangs on your suspicion, not on a threshold. In the UK the report is a suspicious activity report to the National Crime Agency; in Belgium it goes to the CTIF-CFI, in the Netherlands to FIU-Nederland and in France to Tracfin. Tipping off the customer is a separate offence in all four.
Vintro Pro keeps the purchase price, the date and the invoice with every piece. Years on they still sit together — which is exactly what the record-keeping rules ask for.
30 days free, no card number.