The Art Law Podcast The Art Market Integrity Act: Are AML regulations finally coming to the US art market?
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Oct 14, 2025 Jane Levine, a regulatory and compliance expert in the art market and former chief global compliance counsel at Sotheby's, dives into the critical topic of anti-money laundering (AML) regulations in the U.S. art world. She discusses the implications of the proposed Art Market Integrity Act and its efforts to amend the Bank Secrecy Act. Topics include beneficial ownership checks, the cultural barriers to client due diligence, and the drive behind the legislation aimed at curbing illicit financing. Levine emphasizes proactive compliance measures and how art businesses can adapt to new regulations.
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Art Market May Join Bank Secrecy Act
- The Art Market Integrity Act would fold the art market into the Bank Secrecy Act framework.
- That would enable Treasury/FinCEN to impose AML, KYC, and compliance program requirements on art-market participants.
Always Verify Beneficial Ownership
- Ask about beneficial ownership for opaque entities and verify human owners.
- Obtain identifying information and documents when ownership or payment details do not match.
Scale AML Programs By Risk
- Treat AML obligations as risk-based and scale your program to your client profile.
- Low-risk businesses can adopt lighter procedures like basic ID checks and documented client knowledge.