In a typically well-researched and referenced text, Cultural Heritage Lawyer Rick St Hilaire gives a useful and interesting summary of the situation regarding anti-money laundering and counter-terrorism financing legislation (AML/CTF) in relation to the international art market ('Money Laundering and the Trade in Cultural Property: Taking a Fresh Look at Federal AML/CTFs', 25 Jan 2014). It is a shame that there are so few comparable resources on the English-speaking Internet where the average collector can go for this sort of information presented in such a professional and objective manner.
We are all witness to current attempts of US antiquities dealers to free themselves of compliance with import regulations on cultural property aimed at limiting passage of smuggled goods to the US. Organized criminal groups are heavily involved in smuggling operations, so it is worth noting that the U.S. Department of State's INL Office of Anti-Crime Programs (referenced by St Hilaire) specifically cites "art dealers" when discussing AML/CTF goals.
St Hilaire gives a succinct introduction to money-laundering practices, and how it interacts with legitimate sectors of a grey market. He has already proposed spotlighting black market antiquities with record-keeping laws and now points out that:
identifying and targeting both money laundering and terror financing that is entangled within the legitimate cultural property trade should also involve a fresh look at federal AML/CTFs, and maybe some changes.
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