On 24 March, Crowell Moring reported that FinCEN had published its first Notice related to one of the many changes made in the Anti-Money Laundering Act of 2020, passed as part of the National Defense Authorization Act 2021. Its guidance informs financial institutions about the AML Act’s provisions related to trade in antiquities and art, underscores that illicit activity related to antiquities and art may involve financial institutions and trigger reporting requirements, and provides specific instructions for filing SAR related to suspicious activity involving antiquities and art. The AML Act broadened the definition of “financial institutions” in the Bank Secrecy Act. According to FinCEN’s Notice, illicit activity involving trade in antiquities and art might include looting, theft, illicit excavation of archaeological items, smuggling, the sale of stolen or counterfeit items, money laundering and sanctions violations.
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