I recently came across (by way of this article on White & Case's website) a new report from the FATF, entitled "Money Laundering and Terrorist Financing in the Art and Antiquities Market." It is a 40-page report (plus appendices) that appears to give a solid overview of this often-obscure topic, including discussions of money laundering vulnerabilities, the role of both organized crime groups and terrorist organizations, and recommendations for best practices.
From the website:
The market of [sic] art, antiquities and other cultural objects has attracted criminals, organised crime groups and terrorists to launder proceeds of crime and fund their activities. Criminals seek to exploit the sector’s history of privacy and the use of third-party intermediaries while terrorist groups can use cultural objects from areas where they are active to finance their operations.
The vast majority of market participants do not have a connection to illicit activities, but there are risks associated with these markets and many jurisdictions do not have sufficient awareness and understanding of them. This results in a lack of investigative resources and expertise, and difficulties with pursuing cross-border investigations.
The report includes a list of risk indicators that can help public and private sector entities identify suspicious activities in the art and antiquities markets, and also highlights the importance of rapidly identifying and tracing cultural objects involved in money laundering or terrorist financing.
The report includes some good practices that countries have taken to address the challenges they face, including the establishment of specialised units and access to relevant databases and cooperation with experts and archaeologists to help identify, trace, investigate and repatriate cultural objects.
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