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Anti-Money Laundering Fine Art

Ballard Spahr LLP

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

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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

K&L Gates LLP

Key Lessons: The Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

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On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more

White & Case LLP

Money Laundering Issues in the Art Market

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In February 2023, the Financial Action Task Force (“FATF”), the global standard-setter on Anti-Money Laundering policy, issued a report describing the financial crime risks in the art and antiquities market, as well as good...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

BakerHostetler

Treasury Department Releases AML Study on the Art Market

BakerHostetler on

On Jan. 1, 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA) which expanded the definition of “financial institution” to impose anti-money laundering (AML) requirements on persons “engaged in the trade 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

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

Sullivan & Worcester

The Trotter Interview Files: Nick O’Donnell of the Art Law Report

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Last week the Trotter chatted with her partner and fellow blog editor, Nick O’Donnell. Nick’s practice focuses primarily on complex civil litigation, for which he has appeared before the Supreme Court of the United States....more

Miles & Stockbridge P.C.

Top 5 Changes To Anti-Money Laundering Requirements

On January 1, 2021, the National Defense Authorization Act became law after Congress overrode the President’s veto. As highlighted below, Congress enacted a variety of key provisions that create significant and sweeping...more

Ballard Spahr LLP

Art and OFAC

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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

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

Ballard Spahr LLP

Using Art to Evade Sanctions and Launder Money: The Senate Report

Ballard Spahr LLP on

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

K2 Integrity

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

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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

Cohen & Gresser LLP

The New UK Anti-Money Laundering Regulations: How Will The Art World Be Impacted?

Cohen & Gresser LLP on

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...more

BCLP

A rag-bag of changes to UK money laundering regulations

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UK regulations implementing the EU 5th Money Laundering Directive (“5MLD”) came into force on 10 January 2020: the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (“MLR 2019”). The regulations make a...more

WilmerHale

Avoid Shades of Grey: Anti-Money Laundering Regulation Comes to the Art Market

WilmerHale on

A new law, which came into force on 10 January, has ushered in material changes to the regulation of the art market, extending the application of the UK’s anti-money laundering legislation to the sector. The new law,...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

Sullivan & Worcester

Recap and Analysis: Responsible Art Market Initiative Launched in Geneva

Sullivan & Worcester on

I was pleased to attend last week in Geneva “Building an Art Market for the Future—Guidelines for Countering Money Laundering and Terrorist Financing Threats” hosted by the Fondation pour le Droit d’Art (Art Law Foundation)...more

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