From Recommendations to Results: Marking the 5th Anniversary of the Financial Crimes Task Force Report
September 24, 2025
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.