Financial crime developments in the art and luxury goods markets

On 22 January 2024, the UK National Crime Agency (NCA) published an amber alert (the NCA Alert) relating to the “art storage sector”, pointing out risks associated with money laundering, sanctions evasion, and arts trafficking for participants in the sector. The term “art storage sector” as defined by the NCA covers not only warehouses and freeports but also auction houses, art galleries, art dealerships and museums, which are used to “hold, store or move” artworks.

The NCA Alert reflects some key sanctions actions in 2023 by authorities in the U.S. and the UK.  With regulators on both sides of the Atlantic continuing to scrutinize the art market, now more than ever, art market participants and related service providers should ensure that they have compliance systems in place to address potential financial crime risks.