On 10 January 2020 the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (the “2019 Regulations”) came into force in the UK, implementing the EU’s fifth Money Laundering Directive (“MLD5”) and amending the fourth Money Laundering Directive. The 2019 Regulations extend anti-money laundering responsibilities to UK art market participants (“AMPs”), including art dealers and other intermediaries. The extension of MLD5 to AMPs is a response to the increasing recognition that high-value art is used by criminals and terrorist groups to launder and hide money. Accordingly, individuals and firms within the art market must implement appropriate procedures to guard against the facilitation of money laundering.
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