Last week, the U.S. Department of the Treasury released a report entitled “Study of the Facilitation of Money Laundering and Terror Finance Through the Trade in Works of Art” that discussed risks in the art sales ecosystem, ranging from high-value traditional art to NFTs and online sales platforms. Section 6110(c) of the Anti-Money Laundering Act of 2020 (AMLA), enacted as part of the National Defense Authorization Act for Fiscal Year 2021, had directed the U.S. Department of the Treasury to study the facilitation of money laundering (ML) and terror finance (TF) through the trade in works of art (the “Study”). The Study discusses which art market participants and sectors of the high-value art market in the United States present ML and TF risk, and that as a result may warrant regulation as financial institutions under the Bank Secrecy Act.
