I was honored to be among the speakers this week at the United States Holocaust Memorial Museum on March 5, 2024. Convened by the World Jewish Restitution Organization and the U.S. State Department, the event announced the...more
The U.S. Court of Appeals for the 9th Circuit ruled on January 9, 2024 that the Thyssen-Bornemisza Collection Foundation in Madrid is the owner of Rue Saint–Honoré, après-midi, effect de pluie (1892) by Camille Pissarro, a...more
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
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
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
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
The Anti-Money Laundering Act of 2020 (the “AMLA”), which became law January 2, 2021 with Congress’ override of then President Trump’s veto of the Defense Appropriations Act of 2021 included provisions bringing dealers in...more
As we’ve blogged, high-end artwork can create an ideal vehicle for money laundering. And, as we’ve also blogged, the Permanent Subcommittee on Investigations for the U.S. Senate released in July 2020 a detailed report titled...more
Last week, the Office of Foreign Assets Control (OFAC) issued an Art Advisory, warning of the sanctions risk presented by high-value artwork transactions due to the anonymity, lack of transparency, mobility of assets, and...more
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
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
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
Is Art an “Ideal Playing Ground” for Money Laundering? Last week, the Permanent Subcommittee on Investigations for the U.S. Senate released a detailed, 147-page report titled “The Art Industry and U.S. Policies That...more
Since online auctioneer Paddle 8 filed for bankruptcy protection in March, creditors of the company have begun filing their notices of claim in the bankruptcy case. One thing on which the creditors all seem to agree is that...more
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
News broke last week that auction house Christie’s had agreed to pay a $16.7 million fine to the Manhattan District Attorney for failing to collect sales tax between 2013 and 2017. This was surprising in many ways, but a...more
The introduction of the Fifth Money Laundering Directive on the 10th January 2020 brought the art market into the fold of regulated sectors for anti-money laundering purposes. The new law, which amends the existing...more
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
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
The potential role of high-end art and antiquities in money laundering schemes has attracted increasing attention over the last several years, particularly as the prices for such objects steadily rise and a tightening global...more
In recent art world news, British artist David Hockney’s iconic painting “Portrait of an Artist (Pool with Two Figures)” (1972) set an auction sale record for a living artist when it sold for an astonishing $90.3 million in...more
In recent art world news, as an update to our recent post on the fall sale of American works from the $300 million Barney Ebsworth collection, the highly anticipated sale of American modern art occurred earlier this week and...more
In recent art world news, more than 85 works from Barney Ebsworth’s art collection will be on the auction block in November at Christie’s in New York. The late travel entrepreneur’s collection is estimated at over $300...more
After four months of silence, the Berkshire Museum suddenly demanded last week that my clients dismiss their still-pending lawsuit over the governance of the museum by claiming that the April decision by the Single Justice of...more
In recent art world news, Sotheby’s reported a $57.3 million net income in the second quarter of this year in a recent earnings call earlier this week. This figure represents a decrease of $19.6 million or about 26% in...more