On February 4, 2022, the Treasury Department published its Study on the Facilitation of Money Laundering and Terror Finance Through the Trade in Works of Art (the “Report”).[1] To the surprise of many and the relief of the U.S. art market, the Report concluded that there was no immediate
Continue Reading U.S. Treasury Study Rejects Immediate Need for New Regulation of Art Market
On January 1, 2021, Congress voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021,[1] which includes provisions that will have significant implications for the antiquities market, and could eventually impact the art market as well.
The New Legislation Extends Bank Regulations to
Continue Reading National Defense Authorization Act Imposes Anti-Money Laundering Regulations on Antiquities Market and Calls For Study on Role of Art Market in Money Laundering
On October 30, 2020, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”), which administers and enforces American economic sanctions, issued an advisory titled “Advisory and Guidance on Potential Sanctions Risks Arising from Dealings in High-Value Artwork” (the “Advisory”). OFAC considers “high-value” any artwork valued at over
Continue Reading OFAC Issues Advisory on Sanctions Risks in Dealing with High-Value Artwork
On July 29, 2020, the Senate Committee on Homeland Security and Governmental Affairs issued a 150-page bipartisan report that identifies the art market both as the “largest legal, unregulated market in the United States” and a significant weakness in the nation’s sanctions and anti-money laundering regimes.[1] The Senate Report
Continue Reading Senate Report Documents Russian Oligarchs’ Use of the U.S. Art Market to Launder Money