Art Market Operators (“AML Standards”) and Responsible Art Market, or RAM Standard are very comprehensive and tie in closely with EU Standards in AML4.
"These AML Standards adopt a “risk-based” approach to establishing measures to mitigate money laundering risks, and further note that small businesses may not have the resources to address money-laundering risks in the same way that large auction houses or major dealers and galleries will have, and may have a different risk exposure." The question remains - how can I do this efficiently (cost) and effectively (risk appetite) without major investment in technology?