How tighter AML legislation will affect the art world   

Dark arts: How tighter AML legislation will affect the art world

The EU's Fifth Money Laundering Directive will regulate all UK art market transactions above a threshold of €10,000 from January 2020, adding a further layer of compliance on top of sanctions legislation that already restricts dealing with certain entities. Helen Mulcahy, Francesca Titus and Vivien Davies consider the impact of the new rules and discuss how those trading in the art market can prepare for increased scrutiny.



It is increasingly common for authorities to pursue criminal proceedings against businesses for a wide range of offences, from bribery and financial crime, to corporate manslaughter/health & safety, tax, competition and regulatory infringement. We have significant experience in dealing with criminal and regulatory investigations, often in full public glare, across multiple jurisdictions. This includes interviews under caution and defending criminal prosecutions.  We also have a team of rapid response specialists who can attend raids on your premises.

The starting point for any alleged business crime is to find out what actually happened. As lawyers, investigations that we are involved with can carry legal privilege which allows you to gather information in a confidential manner.

We understand how to interact with authorities in a way that safeguards your position; managing disclosure of information, and advising on "self-reporting"; taking account of public interest issues, and the extent to which authorities will negotiate.

We also help clients who are innocently mixed up in the wrong-doing of others respond to requests for information and evidence, from investigation through to trial support.


Keep up to date with the latest Bribery and Corruption developments with our SFO Investigations Tracker and Enforcement Trends table


Notable deals / highlights

  • Advised a global bank in connection with a fraud prosecution in Belgium and represented it throughout the trial process.

  • Undertook a multi-jurisdictional corruption investigation for a US based global corporation, and advised on "self-reporting" to regulatory and prosecutorial authorities.

  • Represented an international travel company and its employees in connection with a criminal prosecution in Greece for manslaughter and related issues.

  • Advised a major UK company that had been fined through its US operations for a breach of the US Foreign Corrupt Practices Act, on issues arising from its contractual arrangements in Iran.

  • Advising an international oil company with exploration and production interests in Syria on the impact of successive EU sanctions on its business.

  • Conducting caution interviews.

  • Successfully defending regulatory investigation of company and individual directors.

  • Advising business in the regulated sector facing prosecution for failing to make a SAR pursuant to the Proceeds of Crime Act.

  • Attending client offices to advise on an emergency basis during a 'dawn raid' by police seeking documents.

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