Luke Messer, an Indiana Congressman, has introduced the Illicit Art and Antiquities Trafficking Prevention Act, HR 5886. The bill adds "dealers in art and antiquities" to the Bank Secrecy Act.
This means that art and antiques dealers and sellers must now:
(1) Establish an effective BSA compliance program.
(2) Establish an effective customer due diligence system and monitoring program.
(3) Establish an effective Suspicious Activity Report (SAR) process.
(4) Screen clients against OFAC and other sanctions list.
(5) Keep records of cash purchases and file reports of cash transactions exceeding $10,000.
Given that money launderers are known to purchase fine art and antiques, for the purposes of laundering the proceeds of crime of their clients, the extension of the Bank Secrecy Act to fine art and antiques is a step forward.
This means that art and antiques dealers and sellers must now:
(1) Establish an effective BSA compliance program.
(2) Establish an effective customer due diligence system and monitoring program.
(3) Establish an effective Suspicious Activity Report (SAR) process.
(4) Screen clients against OFAC and other sanctions list.
(5) Keep records of cash purchases and file reports of cash transactions exceeding $10,000.
Given that money launderers are known to purchase fine art and antiques, for the purposes of laundering the proceeds of crime of their clients, the extension of the Bank Secrecy Act to fine art and antiques is a step forward.
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