Month: September 2025

From Recommendations to Results: Marking the 5th Anniversary of the Financial Crimes Task Force Report

Posted on by Parker Blackwell

Turning Policy into Practice to Protect Consumers, Safeguard Art and Culture, and Strengthen the Art Market

Five years after the Antiquities Coalition’s Financial Crimes Task Force first sounded the alarm on the risks facing the U.S. art market, major reforms are underway—but critical work remains. Congress has already extended anti–money laundering laws to antiquities dealers, and a bipartisan bill is now before lawmakers to expand these protections across the art market. At the same time, opportunities remain for the U.S. government to act on other Task Force recommendations and close persistent gaps that criminals continue to exploit.

On September 24, 2020, the Antiquities Coalition’s Financial Crimes Task Force published its joint report, Reframing U.S. Policy on the Art Market: Recommendations for Combating Financial Crimes. 

This white paper documented risks facing the American art market: from money laundering to terrorist financing, sanctions violations, tax evasion, fraud, forgery, and other related crimes. More importantly, it put forward 44 recommendations to fight back, including new policies, practices, and priorities that could be implemented by the U.S. government, art market, financial industry, and international community.

Five years later, several key priorities have seen major progress. In 2021, Congress extended anti-money laundering (AML) laws to antiquities dealers through the National Defense Authorization Act. Then, earlier this year, a bipartisan group of Senators introduced the Art Market Integrity Act, which would expand these protections to high-risk art transactions more broadly. Together, these efforts represent a major step forward in making the U.S. art market more responsible, transparent, and protective of consumers. 

Other recommendations have helped to spur further action across government agencies, financial institutions, and the art market, including: 

  • In 2022, the Government Accountability Office (GAO) released a sweeping report on trafficking and money laundering by transnational criminal and terrorist organizations, highlighting how illicit actors use trade-based schemes, shell companies, and high-value goods (including art and antiquities) to launder criminal proceeds. The GAO urged U.S. agencies to strengthen coordination and risk assessments in response, reinforcing the need for greater oversight of the art market. (Recommendation 3)
  • That same year, the U.S. Department of Treasury called for strengthened AML and counter-terrorist financing measures for the American art market, warning no fewer than 30 times that “high-value art and the market in which it is traded can be abused by illicit financial actors.” (Recommendation 7)
  • In 2023, the Department of Justice indicted Hezbollah-financier Nazem Ahmad for using art and luxury goods to bypass terrorist-related sanctions, enabling transactions of over $160M in the United States. (Recommendation 17)
  • In 2024, Treasury’s National Strategy for Combating Terrorist and Other Illicit Financing and Supporting Risk Assessments reaffirmed that unregulated high-value sectors pose serious risks to the U.S. financial system, underscoring the continuing need for reform. (Recommendation 7)

These milestones mark real progress, but there remains an opportunity for the U.S. government to advance other Task Force recommendations. For example: 

  • The Department of Justice should establish an office of cultural heritage crimes prosecutors to bring cases against individuals and organizations who commit crimes through the art market, such as antiquities trafficking, money laundering, and fraud. (Recommendation 11)
  • All national customs and law enforcement agencies should contribute data on their cultural property seizures to the World Customs Organization (WCO), for inclusion in its annual Illicit Trade Report. (Recommendation 29)
  • A group modeled after the Jewelers Vigilance Committee could be created, which would provide guidance to art dealers in understanding compliance obligations, creating AML risk assessment programs and policy, and educating staff. (Recommendation 38)

Significant additional progress on many recommendations could also be achieved through two key actions now before policymakers:

  • Finalizing Treasury’s rulemaking on antiquities dealers. While again Congress extended the Bank Secrecy Act to the antiquities trade in 2021, the law cannot be fully enforced until Treasury issues implementing regulations. Finalizing this rulemaking is critical to ensuring that antiquities dealers adopt the same anti–money laundering safeguards already required of other high-risk sectors.
  • Passing the Art Market Integrity Act. This bipartisan bill would extend those same protections to the broader art market, requiring customer due diligence, risk assessments, and compliance programs for high-value art transactions. 

Taken together, these two steps represent the most immediate opportunities for advancing the Task Force’s vision and building on the progress of the past five years. As we mark this anniversary, we celebrate the progress made while remaining committed to advancing the report’s recommendations to protect consumers, safeguard cultural heritage, and strengthen the global fight against financial crimes.

Read the FCTF Report.

Learn more about the Art Market Integrity Act.

The Hunt for the Prakhon Chai Hoard Continues: AC Interviews Dr. Tanongsak Hanwong

Posted on by Parker Blackwell

In this two-part blog series, the AC returns to the question: How did Douglas Latchford—who for decades was a “one-man supply-and-demand” of cultural treasures looted from the Southeast Asian nation of Cambodia—first launch his criminal career? According to groundbreaking research, the answer lies in a little known case from 1960s Thailand. 

We sat down with international experts, whose recent investigations are shedding light on how Latchford built his criminal empire, long before his better-known operations in Cambodia. The Prakhon Chai Hoard—a collection of Buddhist bronze sculptures (7th–9th c. CE) looted from the Plai Bat II Temple complex in southeastern Thailand—represents one of the earliest chapters in Latchford’s long career of cultural racketeering.

The bronzes’ origin and path into Western museums and collections—long debated—are becoming clearer thanks to the extensive work of Dr. Tanongsak Hanwong and his research team, including Dr. Lalita Hanwong and Dr. Stephen A. Murphy. Their recently published findings about the Prakhon Chai Hoard case also reveal previously unknown details of Latchford’s criminal activity before his trafficking operations in Cambodia, where he relied on many of the same accomplices and smuggling techniques.

Following up on our recent discussion with Dr. Angela Chiu about the enduring consequences of this type of cultural plunder, the AC was pleased to speak with Dr. Tanongsak Hanwong,* an archaeologist and member of a Thai government committee for the repatriation of stolen artifacts, to discuss what this latest repatriation reveals about accountability in the art world—and what must come next. 

Learn more. Read Hanwong et al’s article, “The Prakhon Chai Hoard Debunked: Unravelling Six Decades of Myth, Misdirection, and Misidentification.”