Friday, September 13, 2019


Money launderers have been placing and sanitizing criminal proceeds for decades, by purchasing fine art and antiques for cash, quietly transporting these types of assets. from countries where the money is acquired, into countries where the cleaned cash can be openly invested, or to repatriate that wealth for their cartel clients.

After all, putting an Old Master worth many millions into a second-hand frame, assuring its obscurity by dumping it into a box of cheap art prints, to be thereafter shipped in international commerce, unrecognized by Customs officers, and sold to a local art dealer. Whether the laundryman's goal is to simply move wealth across international borders, or to clean the proceeds of crime, art and antiquities, an industry thus far excluded from the compliance requirements of the Bank Secrecy Act (BSA), is a favorite avenue of international money launderers working for cartels and transnational criminal organizations.  

The United States is attempting to bring the arts and antiquities industry into the orbit of the BSA. House of Representatives Bill 5886, captioned the Illicit Art and Antiquities Trafficking Prevention Act, which amends the Bank Secrecy Act to require art and antiquities dealers to comply with the BSA provisions regarding creation of compliance  program and manual, reporting, record keeping, training, and auditing.

Readers who wish to review the House Bill will find the complete text below.

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