From Ancient to Post-Modern: Arts, Antiquities, and U.S. AML

Money Laundering Bulletin


In this article, Litigation Member Matthew Reinhard discusses the new compliance challenges that the art and antiquities markets may face with the new regulations put in place by the 2021 Defense Authorization Act (DAA). The DAA contains a significant overhaul and expansion of the U.S. anti-money laundering (AML) regime, Reinhard wrote, including increased attention to the use of shell companies, to international cooperation amongst AML regulators, to a new focus on entities that may be used as conduits for illicit financial flows and terrorist financing. "Antiquities dealers will be covered by the U.S. anti-money laundering regime and art dealers surely can't be far behind. So much is clear but scope and detail are not," Reinhard wrote, adding that while there may be new challenges, there is a unique opportunity for dealers to influence the scope of forthcoming regulations as well sufficient time to prepare for the new regime.