Historically, the art and antiquities markets have been characterised by robust discretion but limited regulation, features that have long made them a potential target for financial crime.

But this is now changing, with the EU, UK and US introducing regulation to prevent these sectors from being used for money laundering, sanctions evasion, fraud, and the illicit transfer of goods and wealth. The reality for advisers dealing with clients who invest in or collect art and antiquities is that more regulation is in the pipeline that they need to be aware of.

Financial crime risks 

Recent headlines have made clear that the risk of financial crime in the art and antiquities markets is not hypothetical. The Pandora Papers revealed offshore trusts used to shield assets accumulated by trafficking in looted Cambodian artefacts. Disgraced Malaysian financier Jho Low forfeited a Picasso, Monet and Basquiat to US authorities in 2018.

Repeated revelations of fraudulent art-based investment schemes have landed in New York courts in the past few years, and seemingly regular stories arise regarding forged artworks, money laundering through purchase and sales, art used for organised crime collateral, and antiquities trafficking tied to terrorist financing.



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