Financial Crimes Task Force



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.

Full Report Here

Recommendations Overview Here

Executive Summary Here


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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