Vintro Pro Knowledge base · Legislation

When does an antique dealer fall under money laundering rules?

From £10,000 in the UK, and €10,000 across the Channel, duties apply that do not exist below: identify the customer, keep records ten 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.

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 ten years later. 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.

Two thresholds that get confused

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.

10,000 — are you regulated?

  • What it governs: whether you must identify the customer, keep records and hold a written procedure.
  • Per what: per transaction, or per series of linked transactions. Splitting does not help.

3,000 — may it be cash?

  • What it governs: how much of the price may cross the counter in notes. In France 1,000 euros; in the UK no cap at all.
  • Per what: per sale, on the total — instalments included.

No threshold — the report

  • What it governs: what you do when something does not feel right. The Belgian law says literally “whatever the amount”.
  • Per what: per transaction, and in principle before it is carried out.

The UK no longer counts in euros — and does not say so yet

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.

When you are regulated, in four countries

The number is 10,000 everywhere. The currency is not.

UK £10,000

pounds, not euros — reg. 14 MLR 2017, amended 30-06-2026

BE €10,000 and 50 years

“more than fifty years old” — art. 5, §1, 31°/1

NL €10,000

works of art, no age test — art. 1a(4)(k) Wwft

FR €10,000

“égal ou supérieur” — art. L561-2, 10° CMF

Every card comes from the legislation itself, consulted on 15 September 2026: the Money Laundering Regulations 2017 via legislation.gov.uk, the Belgian law of 18 September 2017 via the Justel database of the Belgian Official Gazette, the Wwft via wetten.overheid.nl, and the Code monétaire et financier via Légifrance.

What may be paid in cash, in the same four countries

This limit has nothing to do with the previous one, and the gap between Belgium and the Netherlands comes down to a single word.

UK No cap

but from £10,000 in cash: high value dealer

BE More than €3,000: no

art. 67(2) — exactly 3,000 is still allowed

NL €3,000 or more: no

art. 1f Wwft — exactly 3,000 is already too much

FR Above €1,000: no

art. D112-3 CMF — €15,000 for a non-resident

UK: regulation 14(1)(a) MLR 2017, the definition of high value dealer. Belgium: article 67(2) of the law of 18 September 2017. Netherlands: article 1f of the Wwft. France: article D112-3 of the Code monétaire et financier, in force since 1 October 2018. All four consulted on 15 September 2026.

🧮 Am I regulated?

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.

Regulated?
Cash allowed?

What the texts actually say

Four countries, four legal texts. These are the sentences themselves, not a summary of them.

An auctioneer’s threshold is the estimate, not the hammer

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:

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.

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)(b)(ii).

“More than” is not “or more”

At exactly €3,000 Belgium and the Netherlands part company, and it comes down to two words.

A small gap, and yet it is precisely the figure people round to. The calculator above accounts for it: enter 3000 and switch countries.

One Dutch reporting threshold that was deleted

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.

What is already in your stock list

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. Ten 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 ten years together. An invoice attached to the piece itself does.

Where it goes wrong in practice

Measured on 15 September 2026, each time in the legislation itself. UK: The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulation 14, with the amendment by S.I. 2026/621, via legislation.gov.uk. Belgium: the law of 18 September 2017, articles 5 §1 31°/1 and 31°/2, 21, 47, 55, 60 and 67 §2, via the Justel database. Netherlands: the Wwft, articles 1a(4)(k) and 1f, via wetten.overheid.nl, and the decree at Staatsblad 2026, 99. France: the Code monétaire et financier, articles L561-2 10° and D112-3, via Légifrance.

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.

Frequently asked questions

From what amount does an antique dealer fall under money laundering rules?

From GBP 10,000 in the United Kingdom, and from EUR 10,000 in Belgium, the Netherlands and France. Belgium adds a second condition: article 5(1)(31/1) of the law of 18 September 2017 covers works of art or movable goods MORE THAN fifty years old. A 12,000 euro piece that is thirty years old therefore falls outside that provision in Belgium, while the other three countries catch it. The amount counts per transaction or per series of transactions that appear to be linked: splitting a sale does not help.

Is it true that the UK counts in euros?

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.

Is the cash limit the same amount?

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.

What must I keep, and for how long?

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.

What if I see something suspicious?

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.

Further reading

Who bought it stays with the piece

Vintro Pro keeps the purchase price, the date and the invoice with every piece. Ten years on they still sit together — which is exactly what the record-keeping rules ask for.

Free up to 10 pieces, no card number and no end date.