Financial Crimes Task Force


The U.S. government and private sector must work together to bar criminals from exploiting the $28.3 billion American art market—the largest unregulated market in the world—or risk serious consequences for the country’s national security and economic integrity, as well as legitimate collectors, dealers, auction houses, and museums.

The Antiquities Coalition’s nonpartisan think tank convened the Financial Crimes Task Force to further this mission and serve as an ongoing resource to policymakers. The 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.

We hope that these recommendations and accompanying resources, developed by industry leaders, will help to cement America’s standing as a leader in the fight against financial crimes.


The $28.3 billion 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.


Art, Antiquities and Financial Crimes: A Collection of Case Studies curated by the Financial Crimes Task Force of the Antiquities Coalition

In recent years, a growing number of scandals, investigations, prosecutions, and convictions have demonstrated the art market’s dangerous vulnerability to a wide range of financial crimes. This interactive StoryMap illustrates case studies from around the world. While the United States remains the world’s largest art market, and thus dominates any survey, these examples make clear this is a global problem. The cultural objects involved likewise span geography, as well as history, from ancient relics, to Monets and Van Goghs, to Dalis and Picassos, as well as fakes and forgeries. Sometimes these antiquities and artworks are central to the crimes themselves, but just as often, they are tools to launder the proceeds of artifact trafficking, drug smuggling, embezzlement, corruption, or other crimes. The criminals responsible range from small time crooks to infamous kleptocrats, from white-collar embezzlers to black-clad ISIS thugs. However, they are rarely dedicated collectors or professionals from the art market, but rather bad actors seeking to exploit the sector’s many weaknesses. Thankfully, if the U.S. government and private sector work together, there is much they can do to fight back.


U.S. Anti-Money Laundering Legislation

Unfortunately, dealers, galleries, and auction houses are not yet covered by the Bank Secrecy Act, the United States’ primary anti-money laundering law, which requires at-risk industries to assist the government in preventing and detecting financial crimes. The statute already applies to dealers in precious metals, stones and jewels, as well as sellers of automobiles, planes and boats, casinos, real estate professionals, travel agencies and pawnshops. Congress is continuing a bipartisan push to tackle this major loophole, as seen from this interactive timeline.


Global Anti-Money Laundering Legislation

If the United States fails to act, it risks our own market becoming a safe haven for financial criminals. This is because other major market jurisdictions—including the United Kingdom, Switzerland, and the European Union—have already taken similar action to fight money laundering and terrorist financing in their art markets. This map highlights examples of these and other relevant legislation around the world.


Full Report Here

Recommendations Overview Here

Executive Summary Here


As this report makes clear, there are many immediate and concrete steps that can be taken to bar criminals from exploiting the $28.3 billion American art market, forty four of which are laid out here. We urge the U.S. government to work with the private sector in implementing these recommendations. We believe they will do much to safeguard the United States’ national security and economic integrity—as well as strengthen its responsible art market.


Deborah M. Lehr
Chairman & Founder
Antiquities Coalition
Tess Davis Tess Davis
Executive Director
Antiquities Coalition
John Byrne
Vice Chairman
AML RightSource
Dennis Lormel
DML Associates LLC
Mike Loughnane
Loughnane Associates
Angel Swift
Head of Conduct Management
Wells Fargo
Liz Fraccaro
Antiquities Coalition
Michael Greenwald
Financial Crimes Task Force

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

Theodore Greenberg
APCO Worldwide International Advisory Council Member

Layla Hashemi
Researcher, Transnational Crime and Corruption Center (TraCCC)

Sree M. Iyer

Marilú Jiménez, esq. CAMS

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

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

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