On 28th May, Stephenson Harwood published a briefing saying that, despite fierce resistance from the art world, January 2020 is likely to see the 5th EU Money Laundering Directive take effect in the UK, requiring auction houses and art dealers to undertake AML checks on customers.  It contrasts the current position with the likely position under the new Directive.  EU Member States have until 10th January 2020 to give effect to its provisions.  Even if the UK leaves the EU under a “no deal” situation, the article says that it is unlikely that the government would let UK AML standards fall behind those applicable elsewhere in Europe.  This much was acknowledged by the Department for Business, Energy and Industrial Strategy.   One item it highlights as being of particular relevance to the art market is the provision which requires verification checks to be undertaken in respect of any intermediary who is making a purchase on behalf of somebody else.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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