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Art Dealers Art Collections Fine Art

Sullivan & Worcester

“ENABLERS Act” Pursues Art Market but Threatens Longstanding Protections Against Government Intrusion

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Consistent with efforts in recent years to apply banking laws to the art market, the prospects of passage of a bill in Congress that would apply those rules to a broad category of advisors and attorneys have recently...more

Sullivan & Worcester

Responsible Art Market Initiative­--Intermediaries and Sustainability in the Art Market January 28, 2022 in Geneva

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After a two-year hiatus, the Responsible Art Market Initiative is planning a return to its in-person annual conference at the end of this month in Geneva. For anyone who has attended RAM events or used its catalogue of...more

Sullivan & Worcester

FinCEN Issues Notice of Proposed Rulemaking to Regulate Dealers in Antiquities

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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

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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

Sullivan & Worcester

A Deaccessioning Decision Tree Grows in Brooklyn—Selling Museum Art in Hard Times

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Robin Pogrebin at the New York Times has written an excellent piece on the news that the Brooklyn Museum intends to sell several works from its collection to raise money. The museum explicitly relies on the pandemic-inspired...more

Cohen & Gresser LLP

Senate Report Exposes the U.S. Art Market as a Hotbed for Money-Laundering and U.S. Sanctions Evasion

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A congressional report released on July 29, 2020, by the Senate’s Permanent Subcommittee on Investigations, exposes how Russian oligarchs looking to evade U.S. sanctions are able to exploit loopholes in the art industry....more

Sullivan & Worcester

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

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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

Sullivan & Worcester

No Excuses left—SPK Restitutes Han Baldung Grien to Persecuted Artist's Heirs for Reasons that Germany Denies to Jewish Victims

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The Stiftung Preussischer Kulturbesitz (Prussian Cultural Heritage Foundation, or SPK) in Berlin announced that it had agreed to restitute a 1537 painting of the biblical figure Lot by Hans Baldung Grien to the heirs of Hans...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

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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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