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Bank Secrecy Act › FinCEN › Art Dealers

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
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

Sullivan & Worcester

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

Sullivan & Worcester on

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

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 

Eversheds Sutherland (US) LLP on

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

Ballard Spahr LLP on

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

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

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

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