The American art market is the largest unregulated market in the world, making it vulnerable to a wide range of financial crimes. This ongoing exemption from standard laws and oversight, which now cover all industries of comparable risk and size, is a documented and growing threat to our national security and integrity, as well as the vast majority of legitimate collectors, dealers, auction houses, and museums. Unless and until the U.S. public and private sectors close these loopholes, they will leave wide open the world’s biggest economy to money launderers, artifact traffickers, drug smugglers, kleptocrats, oligarchs, terrorists, and the many other criminals proven to have exploited the art market’s weaknesses.
The Financial Crimes Task Force, the first of its kind, unites allies from the cultural heritage, financial, and legal communities, as well as former law enforcement and government officials. This diverse group of experts has worked together to develop recommendations for protecting the American art market from money laundering, terrorist financing, sanctions violations, tax evasion, fraud, forgery, and related crimes.
On September 24, 2020, the Task Force published their first joint report, Reframing U.S. Policy on the Art Market: Recommendations for Combating Financial Crimes. It details documented risks facing the American art market from money laundering, terrorist financing, sanctions violations, tax evasion, fraud, forgery, and other related crimes. More importantly, it puts forward 44 recommendations to fight back, including new policies, practices, and priorities that can be implemented by the U.S. government, art market, financial industry, and international community.
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Deborah M. Lehr Chairman & Founder Antiquities Coalition |
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Tess Davis Executive Director Antiquities Coalition |
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John Byrne Vice Chairman AML RightSource |
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Dennis Lormel President DML Associates LLC |
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Mike Loughnane President Loughnane Associates |
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Angel Swift Head of Conduct Management Wells Fargo |
The Financial Crimes Task Force members have reached a consensus around the general report and its policy recommendations, although each individual member does not necessarily endorse every finding and conclusion. Each member has participated in their individual capacities and not as representatives of their institutions.
John Byrne
Vice Chairman, AML RightSource
Laura S. Ballman
Founder, Culture Matters LLC
Alessandro Chechi
Art Law Centre, University of Geneva
William Cloninger
AML Investigations, KeyBank
Brian Daniels
Penn Cultural Heritage Center, University of Pennsylvania Museum
Justine Ferland
Art Law Centre, University of Geneva
Betsy Feuerstein
Attorney and Independent Consultant
Bonnie Goldblatt
Citigroup
Theodore Greenberg
APCO Worldwide International Advisory Council Member
Layla Hashemi
Researcher, Transnational Crime and Corruption Center (TraCCC)
Sree M. Iyer
PGurus.com
Marilú Jiménez, esq. CAMS
FincAdvisors
Lester Joseph
Wells Fargo & Company
Herbert V. Larson, Jr.
Tulane University School of Law
Colette J. Loll
Founder and Director, Art Fraud Insights, LLC
Dennis M. Lormel
President & CEO, DML Associates, LLC
Michael J. Loughnane
President, Loughnane Associates, LLC
Donna M. Luisi
Senior Criminal Analyst, Department of Homeland Security/New York HIFCA
Rick McDonell
Executive Director, ACAMS
Audra McKay
Robinhood Financial Crimes Monitoring Program Manager
Jack Oskvarek
SVP BSA Executive Director, Wintrust Financial Corporation
Gregory Radke, CFE, CISA
Senior Examiner, Office of Credit Unions | State of Michigan
Anthony Rodriguez
AFEX
Kevin P. Rogers
U.S. Secret Service (Ret), Office of The Inspector General-SSA (Ret)
Anita Saggurti
Bank of America, Art Services
Rick Small
Executive Vice President, Director Financial Crimes, Truist
Tiffany Stevens
CEO & General Counsel, Jewelers Vigilance Committee
Angel Swift
Wells Fargo, Head of Conduct Management
Mary Utermohlen
Program Director, C4ADS
Erik Vingelen
SVP, BSA/AML/OFAC Officer, Banner Bank
Sara Yood
Senior Counsel, Jewelers Vigilance Committee
