On 26 May, an Alert from law firm Pillsbury says that authorities are clamping down on financial crime, and the art market needs to understand and satisfy its compliance obligations as COVID-19 results in heightened criminal activity.  It stresses that art market participants must ensure their AML processes and procedures are up to date and fit for purpose.  It also says that, the historic lack of regulation of the art market combined with high value goods, the use of intermediaries, and the desire for collectors to maintain their anonymity has created an environment that is ripe for exploitation. After reflecting on recent developments, and penalties, it says that it is imperative that those in the art market are aware of their compliance obligations and the increasing scrutiny on this previously unfettered industry.  It says that art market participants must therefore ensure their AML processes and procedures are fit for purpose – making several recommendations.  In summary, the article says that, in general, art market participants need to take appropriate steps to identify and assess the risks of money laundering on their business; and the increasing use of online sales puts the art market at greater risk of breaching its compliance requirements.




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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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