Art Law Report

Bill Introduced in U.S. House of Representatives Would Impose Money Laundering Reporting Requirements on Art Dealers

Posted by Nicholas O'Donnell on May 24, 2018 at 10:00 AM

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 ask).  Sometimes these criticisms lean into suggestions of rampant criminality or money laundering, for which there is actually scant support. That is to say, there is a common suggestion that the lack of a single regulatory scheme over the art market (which is not to say it is unregulated, another misconception) is evidence of participation by dealers or collectors in illicit activity. In fact, as we have written before, the far greater risk is of being used by bad actors trying to launder money through art transactions.  For this and other reasons, we were proud to assist in drafting the Responsible Art Market initiative U.S. country guide and the more recent toolkit that was launched in January.

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Topics: Money laundering, AML Program, Know your customer, KYC, Responsible Art Market initiative, H.R. 5886, Luke Messer, OFAC, Office of Foreign Asset Control, Christie's Inc., Illicit Art and Antiquities Trafficking Protection

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The Art Law Report provides timely updates and commentary on legal issues in the museum and visual arts communities.

The material on this site is for general information only and is not legal advice. No liability is accepted for any loss or damage which may result from reliance on it. Always consult a qualified lawyer about a specific legal problem.

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