• About
    • Mission
    • Team
    • Boards
    • Mentions & Testimonials
    • Institutional Recognition
    • Annual Reports
    • Current & Past Sponsors
    • Contact Us
  • Resources
    • Article Collection
    • Podcast: Art in Brief
    • AML and the Art Market
    • AI and Art Authentication
    • Newsletter
      • Subscribe
      • Archives
      • In Brief
    • Art Law Library
    • Movies
    • Nazi-looted Art Restitution Database
    • Global Network
      • Courses and Programs
      • Artists’ Assistance
      • Bar Associations
      • Legal Sources
      • Law Firms
      • Student Societies
      • Research Institutions
    • Additional resources
      • The “Interview” Project
  • Events
    • Worldwide Calendar
    • Our Events
      • All Events
      • Annual Conferences
        • 2026 Art Law Conference
        • 2025 Art Law Conference
        • 2024 Art Law Conference
        • 2023 Art Law Conference
        • 2022 Art Law Conference
        • 2015 Art Law Conference
  • Programs
    • Visual Artists’ Legal Clinics
      • Art & Copyright Law Clinic
      • Artist-Dealer Relationships Clinic
      • Artist Legacy and Estate Planning Clinic
      • Visual Artists’ Immigration Clinic
    • Summer School
      • 2026
      • 2025
    • Internship and Fellowship
    • Judith Bresler Fellowship
  • Case Law Database
  • Log in
  • Become a Member
  • Donate
  • Log in
  • Become a Member
  • Donate
Center for Art Law
  • About
    About
    • Mission
    • Team
    • Boards
    • Mentions & Testimonials
    • Institutional Recognition
    • Annual Reports
    • Current & Past Sponsors
    • Contact Us
  • Resources
    Resources
    • Article Collection
    • Podcast: Art in Brief
    • AML and the Art Market
    • AI and Art Authentication
    • Newsletter
      Newsletter
      • Subscribe
      • Archives
      • In Brief
    • Art Law Library
    • Movies
    • Nazi-looted Art Restitution Database
    • Global Network
      Global Network
      • Courses and Programs
      • Artists’ Assistance
      • Bar Associations
      • Legal Sources
      • Law Firms
      • Student Societies
      • Research Institutions
    • Additional resources
      Additional resources
      • The “Interview” Project
  • Events
    Events
    • Worldwide Calendar
    • Our Events
      Our Events
      • All Events
      • Annual Conferences
        Annual Conferences
        • 2026 Art Law Conference
        • 2025 Art Law Conference
        • 2024 Art Law Conference
        • 2023 Art Law Conference
        • 2022 Art Law Conference
        • 2015 Art Law Conference
  • Programs
    Programs
    • Visual Artists’ Legal Clinics
      Visual Artists’ Legal Clinics
      • Art & Copyright Law Clinic
      • Artist-Dealer Relationships Clinic
      • Artist Legacy and Estate Planning Clinic
      • Visual Artists’ Immigration Clinic
    • Summer School
      Summer School
      • 2026
      • 2025
    • Internship and Fellowship
    • Judith Bresler Fellowship
  • Case Law Database
Home image/svg+xml 2021 Timothée Giet Our articles image/svg+xml 2021 Timothée Giet Opinion image/svg+xml 2021 Timothée Giet Welcome to the AML Regulations and the Art Market: Our Comparative Study by Jurisdiction (1st ed) is Published
Back

Welcome to the AML Regulations and the Art Market: Our Comparative Study by Jurisdiction (1st ed) is Published

December 6, 2023

COVER 2023

By Andrew Adams

The art market’s reinventions, experimentations, and expansions in media, in collectability, in content, and in location create a constant churn of novel financial problems to solve and opportunities to seize. No surprise, then, that the art market presents the same novelties of form that characterizes other emerging financial markets, and indeed has incorporated financial instruments in the form of non-fungible tokens into new artistic media. No surprise, too, that the art market provides the immediate subject of growing interest by financial regulators and law enforcement.

The European Union’s 2018 spotlight on anti-money laundering in the art market resulted in the 5th Anti-Money Laundering (AML) Directive, a supranational effort that has sparked a still unfolding series of Member State efforts toward implementation. In the United States, the Anti-Money Laundering Act of 2020 similarly promulgated an expansion of AML regulation into the cultural property space, focusing specifically on antiquities markets, and the implementation of that new statute still hovers in the regulatory rulemaking process. Presciently perhaps, the U.S. AML Act arrived in the 2020 National Defense Authorization Act (NDAA), and indeed AML compliance and enforcement, including within the art market, has been a hallmark of the United States’ public discussion of national security interests in the wake of the original Russian invasion of Ukraine in 2014 (as with the U.S. Senate’s Committee on Homeland Security and Governmental Affair’s Staff Report on the art market and U.S. sanctions). The theme of linking AML, art, and national security resurged with the full-scale war launched by Russia against Ukraine in February of 2022, and has formed a key focus of efforts by U.S., U.K., and EU officials, in particular, in seeking to make transparent what many in government perceive to be a uniquely opaque corner of the global economy. 

The Center’s first edition of “Anti-Money Laundering: Regulations and the Art Market” is a valuable resource and one that will only grow in importance as the Center’s country-by-country review expands and responds to novel laws and regulations. With contributions from over a dozen contributing experts, the first edition provides a needed and focused overview of laws on AML due diligence obligations, beneficial ownership registration, and the civil and criminal sanctions that can flow from violations in each covered jurisdiction. As the Center’s efforts to identify expertise and compile information on the current state of AML in the U.S., U.K. and E.U. progress, the utility of this resource for practitioners, for collectors, and for regulators looking to understand the practices and requirements outside their home country will become of increasing utility. Against a globally shifting array of laws, regulations, and enforcement priorities, public and private actors of all stripes in the cross-border art market benefit from the expertise and attention given to these issues by the Center, and we should all look forward to the editions to come.

About the Author:

Andrew Adams, advisor to the Center for Art Law since October 2023, is a partner at Steptoe (NYC). His practices focuses on the areas of government and internal investigations, corporate governance, and white collar and regulatory matters. His practice includes a particular focus on anti-money laundering compliance, U.S. economic countermeasures and national security crisis response, drawing on Andrew’s time as the inaugural Director of the Department of Justice’s Task Force KleptoCapture, a multi-agency response group focused on the economic sanctions and export controls imposed in response to Russia’s invasion of Ukraine.

Disclaimer: This article is for educational purposes only and is not meant to provide legal advice. Readers should not construe or rely on any comment or statement in this article as legal advice. For legal advice, readers should seek a consultation with an attorney.

Post navigation

Previous Introducing: ART IN BRIEF (aka our podcast)!
Next Tempus fugit: If only I had an Apple…

Related Art Law Articles

center for art law AI what digital repatriations could look like against the illusion the limits of digital repatriation in restitution debates
Art lawOpinion

Against the Illusion: The Limits of Digital Repatriation in Restitution Debates

December 8, 2025
Fog Museum Center for Art Law Article
Art lawArt Law HistoryOpinion

Three works from the Harvard Art Museum: How I Introduced Art Law to Educate Visitors

July 22, 2025
Art Law HistoryOpinion

SOLD OUT: Not so Soft and not so Subtle Art of Capitulation

July 18, 2025
Center for Art Law
AML Guide 2025

AML Guide 2025

Explore our updated AML Survey with key insights on how evolving regulations impact the art market.

Download here
Center for Art Law

Follow us on Instagram for the latest in Art Law!

The Gelman Collection, one of the most significant The Gelman Collection, one of the most significant collections of modern Mexican art, is at the center of an ongoing legal and financial controversy. With works by Frida Kahlo, Diego Rivera, María Izquierdo, and others, the collection raises complex questions about the protections afforded to National Artistic Monuments under Mexican law. 

Paula Gutierrez de Villasante examines what the collection's uncertain future could mean for Mexico’s cultural heritage. 

📚Read the full article at the link in our bio!

#ArtLaw #CulturalHeritage #MexicanArt #FridaKahlo #ArtFinance
Learn about Artist Corporations-- exploring what t Learn about Artist Corporations-- exploring what they are, how they work, and the legal and practical considerations for artists!

Please note, this is a hybrid event. Participants are welcome to attend either in person or online via Zoom..

Join the Center for Art Law for Artist Corporations: A New Legal Framework for Creative Practice, a conversation exploring the Colorado Artist Companies Act and what it could mean for artists, lawyers, policymakers, and the broader creative economy.

In 2025, Colorado enacted Senate Bill 133, creating the Artist Corporation (A-Corp); a first-of-its-kind legal business structure designed specifically to recognize and support artists and creative professionals. The legislation offers a new model for balancing artistic practice with sustainable business and legal protections, raising important questions about how the law can better serve creative communities.

Join us for a discussion featuring Lindsay Korotkin, Yancey Strickler, and Sarah Darlene, who will examine the origins of the Artist Corporation, the legislative process behind its creation, and its practical implications for working artists. Drawing on their respective backgrounds in law, advocacy, entrepreneurship, and artistic practice, the panelists will discuss how this innovative legal framework came to fruition, how artists may benefit from it, and whether similar legislation could shape the future of creative industries beyond Colorado.

Following the panel discussion, attendees will have the opportunity to participate in a live audience Q&A as well as a Networking Reception. 

🎟️ Grab your tickets today using the link in our bio!

#centerforartlaw #artlaw #colorado #artistissues
For more than two decades, thousands of counterfei For more than two decades, thousands of counterfeit works attributed to Canadian Anishinaabe artist Norval Morrisseau circulated through galleries, auctions, and private collections. The resulting forgery scandal has made authenticating Morrisseau’s work increasingly difficult and raised larger questions about protecting artists' legacies and the integrity of the art market. 

In her article, Victoria Cook examines the history of the Morrisseau forgery ring and how emerging technologies could help distinguish genuine works from fakes. 

📚 Read the full article at the link in our bio!

1st 📷: Norval Morrisseau, Observations of the Astral World (c. 1994), acrylic on canvas, 236 x 514 cm, National Gallery of Canada, Ottawa

#ArtLaw #ArtForgery #NorvalMorrisseau #IndigenousArt #CanadianArt
Don't miss grabbing tickets for our upcoming Collo Don't miss grabbing tickets for our upcoming Colloquium with Dr Michail Risvas, Lecturer in Law and Co-Director of the Centre for International Law and Globalisation at the University of Southampton, on the growing role of arbitration in the art and cultural heritage sector. 

Drawing on his research and practical examples, Professor Risvas will examine how arbitration is being used to resolve a broad range of art-related and cultural heritage disputes. The program will compare arbitration with traditional litigation, exploring the advantages and limitations of each forum.

Through discussion of case examples and emerging trends, participants will gain a practical understanding of when arbitration may offer a more effective path than litigation and how alternative dispute resolution is shaping the future of art and cultural heritage law.

🎟️ Grab your tickets today using the link in our bio!!

#centerforartlaw #artlaw #legal #artlawyer #lawyer #arbitration #artmarket #artist #culturalheritage
Join the Center for Art Law along with Dr Michail Join the Center for Art Law along with Dr Michail Risvas, Lecturer in Law and Co-Director of the Centre for International Law and Globalisation at the University of Southampton, on the growing role of arbitration in the art and cultural heritage sector. Drawing on his research and practical examples, Professor Risvas will examine how arbitration is being used to resolve a broad range of art-related and cultural heritage disputes. The program will compare arbitration with traditional litigation, exploring the advantages and limitations of each forum.

Through discussion of case examples and emerging trends, participants will gain a practical understanding of when arbitration may offer a more effective path than litigation and how alternative dispute resolution is shaping the future of art and cultural heritage law.

🎟️ Grab your tickets today using the link in our bio!!

#centerforartlaw #artlaw #legal #artlawyer #lawyer #arbitration #artmarket #artist #culturalheritage
And just like that, we’ve reached the end of an in And just like that, we’ve reached the end of an inaugural ART & LAW INTENSIVE ✨

Five-day program filled with challenging questions, fascinating discussions, new perspectives, and meaningful encounters at the intersection of visual art and law.

Grateful for the conversations, the knowledge shared, and everyone who made this experience so enriching. 

Until the next chapter in February!
Our last (August) newsletter received excellent vi Our last (August) newsletter received excellent viewing (in September). Welcome back from vacations! You may be pleased to know that our ART x LAW INTENSIVE in Zurich went as promised and we were delighted to have shared with and learned from so many wonderful experts, colleagues, and fellow travelers. Special guests came from North and South America, across Europe, even India and UAE. Without skipping a beat, today we onboard our Fall 2026 Interns, students from Cardozo, NYU, Smith College and other schools, and we are pleased to welcome our 2026-2027 Judith Bresler Fellow, Alexander Stanfield.

Please take a look at our SEPTEMBER newsletter and plan to join us this fall for in person or online events. Thank you to all who have reached out and offered to volunteer over the summer and recently. We are humbled by the growing interest and will keep offering learning and hands-on opportunities as the size of our organization permits. Stay calm and … 

📚 Click the link in our bio to get a curated collection of art law news, our most recent published articles, upcoming events, and much more!!

#centerforartlaw #artlaw #newsletter #september #legalresearch
What does it take to report and write a story abou What does it take to report and write a story about stolen art, war, and the people caught at the center of it?

In our latest episode of Art in Brief, Andrea and Paris are joined by Matthew Campbell, award-winning reporter for Bloomberg Businessweek and author of The Man Who Stole the Gods, to discuss his years-long investigation into the looting and trafficking of ancient Khmer artifacts from Cambodia.

We talk about Matthew’s research and reporting process, why he chose to center the story around the book’s main characters, and how he approached telling the stories of complicated figures with nuance and empathy.

🎙️ Listen to the latest episode of Art in Brief and find additional resources including a link to Matthew's book at the link in our bio!

#podcast #centerforartlaw #artinbrief #bloomberg #artcrime
What happens to an artist’s work, archives, and in What happens to an artist’s work, archives, and intellectual property after they’re gone? 

Day 2 of the 2026 CPAL Conference brought together lawyers, appraisers, foundation leaders, and arts professionals to tackle the practical realities of preserving artists’ legacies. Topics included estate planning and appraisals, copyright, archives, and the financial realities of running an artist foundation. One message was especially clear: legacy preservation starts long before an artist’s death. 

📚Read Ian Silverstein’s recap of the conference at the link in our bio!

#WYWH #ArtLaw #ArtistEstates #ArtLawConference #ArtAndLaw
Don't miss out on our upcoming Workshop on fiducia Don't miss out on our upcoming Workshop on fiduciary duties within artist-dealer relationships with speaker Aaron Haines!

This workshop will explore the fiduciary duties of gallerists toward their clients and will clarify the distinctions between contract-based relationships and the broader fiduciary obligations gallerists owe, including transparency, prudence, and the prohibition of undisclosed profits. It will also examine common conflicts of interest in the art world and how these fiduciary duties come into play. 

🎟️ Grab your tickets today using the link in our bio!

#centerforartlaw #artlaw #artlawyer #legalresearch #legal #workshop #artistrights #artist #artdealer
The Wilbur J. Cohen Federal Building in Washington The Wilbur J. Cohen Federal Building in Washington, D.C. houses five murals and four reliefs by artists including Ben Shahn and Philip Guston. 
The building is now among federal properties currently slated for sale as the government accelerates selling federal real estate. 

What happens to artworks that are physically inseparable from the buildings they were created for? And what does their uncertain future mean for America’s cultural landscape?

📚 Read Sam Brady-Myerov’s latest article at the link in our bio!

#ArtLaw #CenterforArtLaw #NewDealArt #PublicArt #CulturalHeritage
Did you know the portrait of George Washington on Did you know the portrait of George Washington on the $1 bill traces back to a painting by Gilbert Stuart? 

As the US celebrates its 250th anniversary, one of our latest articles explores how Stuart fought to control the reproduction of his Washington portraits at a time when U.S. copyright law did not yet protect paintings. 

📚 Read the full article by Hannah Gadway at the link in our bio! 

#ArtLaw #America250 #GilbertStuart #GeorgeWashington #CopyrightLaw
  • About the Center
  • Contact Us
  • Newsletter
  • Upcoming Events
  • Internship
  • Case Law Database
  • Log in
  • Become a Member
  • Donate
DISCLAIMER

Center for Art Law is a New York State non-profit fully qualified under provision 501(c)(3)
of the Internal Revenue Code.

The Center does not provide legal representation. Information available on this website is
purely for educational purposes only and should not be construed as legal advice.

TERMS OF USE AND PRIVACY POLICY

Your use of the Site (as defined below) constitutes your consent to this Agreement. Please
read our Terms of Use and Privacy Policy carefully.

© 2026 Center for Art Law