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National Lawyers Guild
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Fractured Atlas

Fine Art and Antiquities Anti-Money Laundering (AML) Compliance

Arts AML ComplicanceNew anti-money laundering regulations came into effect in the United Kingdom in June 2021, and AML regulations for antiquities are anticipated in the United States by 2022. Similar regulations impacting the fine art industry are expected to follow soon thereafter. 

See July 2021 New York Times article about upcoming federal regulation in the United States.

Hrbek Law provides a full service consultancy practice to advise gallerists, art dealers, art consultants and other intermediaries in fine art transactions on the applicable regulations. We can assist with government filings, due diligence and art escrow services. We can provide referrals to fine art insurers and lenders. Art galleries, art consultants, art dealers and other intermediaries need to be very careful who they sell to. Museums, exhibitors and collectors of artworks can also be impacted by the regulations when they transfer items in their collection.

Even before the regulatory regime comes into play in the US, it is a huge concern. Russian oligarchs and drug dealers notoriously seek to hide their illicit gains through cash purchases of real estate and high priced art. Galleries, art dealers and collectors are coming under increasing pressure to help crack down on money laundering through the sale of fine art and antiquities. The regulations place an affirmative obligation on sellers of fine art and intermediaries to conduct due diligence on potential purchasers of artworks. In the UK, galleries and art dealers need to register with the government agency charged with overseeing these sales. If they fail to do so, they can lose their license to operate their business and be subjected to hefty fines.

Deborah Hrbek and Margaret Kunstler are recognized authorities on the UK ad US fine art industry and antiquities regulations, and they follow new developments closely. With a presence in New York, London and Miami, they are well equipped to advise gallery, art dealer, art consultant, museum and collector clients about what regulations apply to their business and what steps need to be taken to stay in compliance.

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