The Fine Art of Auction House Consignments: Art AML, Sanctions Compliance and the Fine Art Owner’s Conundrum**

While the spotlight has recently been on established auction houses anti-money laundering (“AML”), counter-terrorism and sanctions compliance, and the prospect of the United States, like the United Kingdom and the European Union before it, making AML compliance mandatory for art industry protagonists, there appears to be little focus on the broader reluctance of established auction houses to look beyond their relationship with intermediaries in contracts for the consignment of fine art.

While auction houses may be eager to look beyond the identity of the intermediary to enforce its rights, they appear reluctant to do so when it comes to complying with their obligations.

This conundrum can prove problematic not only for sanctions compliance but also for fine art owners who have relied on fine art intermediaries to consign their works of fine art with auction houses.

For art owners, navigating the complexities of this conundrum is, in itself, no less than fine art, and to understand the dynamic it is helpful, first, to look at AML and sanctions compliance and the recent, renewed focus on the fine art industry.

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Sam advises clients on corporate acquisitions and disposals, corporate finance, corporate and partnership structuring and shareholder, operating and buy-sell arrangements, general corporate matters, fine art and cultural property, supply, distribution,  and consignment and inventory management arrangements, and other commercial transactions. Read more about Sam Miller here.

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