New AML Requirements for Art and Antiquities Dealers

The AML Act of 2020 is placing new regulatory requirements on art and antiquities dealers with revisions to Section 6110 of the Act. This section broadened the definition of “financial institutions” pursuant to the Bank Secrecy Act (BSA) to specifically include art and antiquities dealers. And FinCEN is busy getting feedback from industry professionals on how to craft forthcoming regulations. In fact, just recently we saw an interesting case in how increased scrutiny in this sector collided with revelations from the Pandora Papers. 

The art and antiquities market are beginning to take center stage for law enforcement, compliance professionals and the international community. In their report Five Insights into the Art Market and Money Laundering, Deloitte estimates that between $4 and $6 billion in art is stolen and likely laundered each year. In the same report, they project that wealth stored in art and collectibles held by ultra-high net worth individuals will grow from an estimated $1.62 trillion to $2.7 trillion in 2026. 

This means that checks on buyers, sellers and related parties against sanctions, ultimate beneficial owners, corporate structures, negative news and other risks will be key for the industry moving forward. As a provider of compliance technology solutions, Sigma assists the art and antiquities industry in developing robust and responsible compliance programs through the use of purpose built technology. 

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