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Anti-Money Laundering FinCEN Art Dealers

DLA Piper

Art Market Integrity Act Introduced With Bipartisan Support to Combat Money Laundering Risks in the Art Industry

DLA Piper on

Senate Judiciary Committee Chairman Chuck Grassley (R-IA) and Senator John Fetterman (D-PA) have introduced the Art Market Integrity Act (AMIA) in Congress....more

Ballard Spahr LLP

U.S. Senate introduces Act to apply AML/BSA laws to art dealers and auction houses

Ballard Spahr LLP on

On July 23, 2025, Senators John Fetterman (D-PA), Chuck Grassley (R-IA), Sheldon Whitehouse (D-RI), Bill Cassidy (R-LA), Andy Kim (D-NJ), and David McCormick (R-PA), introduced the federal Art Market Integrity Act (the...more

Goodwin

FinCEN Issues Report Addressing NFTs

Goodwin on

On February 4, 2022, the Treasury Department’s Financial Crimes Enforcement Network (FINCEN) jumped into the regulatory discussion about non-fungible tokens (“NFTs”) - more with a whisper than a bang - in a report on its...more

Eversheds Sutherland (US) LLP

Treasury study expresses concern about money laundering risks associated with NFTs 

On February 4, 2022, the US Department of the Treasury (the Treasury) released the “Study of the Facilitation of Money Laundering and Terror Finance through the Trade in Works of Art” (the Report). The Report examines the...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

Ballard Spahr LLP

DOJ Obtains Forfeiture of the Dream Tablet of Gilgamesh

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Case Presages Mandatory BSA Obligations for Antiquities Dealers under the AML Act - In the midst of the invasion of Iraq and the subsequent civil instability, thousands of cultural artifacts were stolen from the National...more

BakerHostetler

Expanded Measures Impose AML Overhaul on Art and Antiquities Market

BakerHostetler on

On July 28, 2020, the U.S. Senate Permanent Subcommittee on Investigations released its findings on the role of the unregulated art market in undermining U.S. sanctions policies and facilitating criminal activity....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

Troutman Pepper Locke

Anti-Money Laundering Act’s Impact on Dealings in Art and Antiquities

Troutman Pepper Locke on

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

K2 Integrity

National Defense Authorization Act (NDAA) 2021: Landmark AML Reforms Pass Congress

K2 Integrity on

In the most consequential update to the Bank Secrecy Act (BSA) since the 2001 passage of the USA PATRIOT Act, the United States Congress on 11 December passed a wide-ranging bill that broadens and updates the BSA and the U.S....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

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