It is widely understood that fine art collectors frequently identify investment as a primary motivation for acquiring fine art. Considering the fluctuating financial markets and prevailing global uncertainties, many fine art...more
A five-year legal dispute between heirs of the renowned artist Thomas Hart Benton and the trust department that administered and managed the Benton Trust produced a significant ruling last month in Jackson County, Missouri...more
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
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
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
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
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
Second of Two Posts on Evolving Issues Regarding Real Estate and Money Laundering - In our last post, we blogged on a major regulatory tool to combat the use of real estate as a potential vehicle for money laundering: the...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
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