On 3/9/21, the Financial Crimes Enforcement Network (FinCEN) issued a notice (FIN-2021-NTC2) to inform financial institutions about (1) the Anti-Money Laundering Act of 2020 (the AML Act)1 efforts related to trade in antiquities and art, (2) select sources of information about existing illicit activity related to antiquities and art, and (3) provide specific instructions for filing Suspicious Activity Reports (SARs) related to trade in antiquities and art. This release encourages financial institutions to continue filing SARs regarding these topics and provides additional guidance.
FinCEN’s guidance can be found here.