News & Analysis as of

Art Collections Anti-Money Laundering

WilmerHale

Money Laundering In The UK Art Market: Key Risks, AML Rules

WilmerHale on

We have been writing a lot recently about trends in the global market for fine art. One specific area that deserves attention is steps taken to stamp out laundering illicit funds via the art market, such as through auctions...more

Sullivan & Worcester

FinCEN Issues Notice of Proposed Rulemaking to Regulate Dealers in Antiquities

Sullivan & Worcester on

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) today published in the Federal Register notice of proposed regulations related to the implementation of amendments to the Bank Secrecy Act (BSA)...more

Sullivan & Worcester

FinCEN Signals Suspicion of Art Market Even Before AML Study Begins

Sullivan & Worcester on

In connection with the late-2020 amendment to the Bank Secrecy Act (BSA) to include “dealers in antiquities” as a result of its inclusion in the National Defense Authorization Act (NDAA), the Treasury Department’s Financial...more

Patterson Belknap Webb & Tyler LLP

OFAC Issues Advisory on Sanctions Risks Arising from High-Value Artwork Transactions

In many ways, the market for valuable art remains one that depends on long-standing relationships and a high degree of familiarity between market participants. The importance of relationships in the art business makes sense....more

Sullivan & Worcester

U.S. Senate Report Takes a Swing at Money Laundering in the Art Market But Strikes Out on Substance

Sullivan & Worcester on

A recent report by the U.S. Senate Permanent Subcommittee on Investigations (headlined by Chairman Senator Rob Portman, Republican of Ohio, and Ranking Member Tom Carper, Democrat of Delaware) has drawn widespread attention...more

K2 Integrity

As COVID-19 Drives More Art Auctions Online, How Do Market Participants Maintain Financial Crimes Compliance?

K2 Integrity on

With the global economy reeling from the direct effects of the COVID-19 pandemic, no sector is spared from its impact, including the art market. As auction houses seek to find ways to sustain business during this time of...more

BCLP

Additional Compliance for the Art World

BCLP on

Individuals, trusts and companies buying or selling art via UK galleries and auction houses will now be subject to the same customer due diligence checks as those opening bank accounts in the UK. What has changed? The...more

K2 Integrity

Art and AML: Regulators Taking a Broad Brush Approach Using Financial Entity Regulatory Compliance as the Model for the Art World

K2 Integrity on

What do people see when they look at a piece of fine art—such as a painting by Cezanne, a sculpture by Giacometti, or a three-dimensional combine by Rauschenberg? To a great extent, it depends on who’s doing the looking. An...more

Sullivan & Worcester

Bill Introduced in U.S. House of Representatives Would Impose Money Laundering Reporting Requirements on Art Dealers

Sullivan & Worcester on

Casting aspersions about the art market is a popular pastime. And no doubt there is much about the commercial art world that invites this criticism, not least a tendency towards secrecy (or discretion, depending whom you...more

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