The War on Money Laundering and Terrorist Financing Extends to Art and Antiquities

Country/area: United States

Organisation: Self-published / CINOA

Organisation size: Small

Publication date: 02/04/2021

Credit: Conor Carman, Clinton Howell, Erika Bochereau


Conor Carman is an art world professional by trade who has been researching and writing on the trade for the past year. By relying on his deep industry knowledge to navigate unique subject matter related to arts and antiquities, he is able to report on the complicated related topics. 

Project description:

A report by the Senate Permanent Subcommittee on Investigations in 2020 called for
tighter anti-money laundering regulations in the U.S. art market. Certain organizations had been urging Congress to tighten regulations on the antiquities trade; others claimed that the Senate Committee may have received misleading data to support new anti-money laundering policy. The future of the trade will require a better understanding of the art/antiquities market by parties on both sides. This project aims to highlight pertinent factors in the decision making, and the catalysts that promoted this legislative move.

Impact reached:

     As a result of this commissioned reporting project, a Belgian art trade organization (CINOA) asked me to spearhead a “trade position paper” for them on the same subject as this project. That position paper was subsequently submitted to the U.S. Treasury for review and consideration upon request:


     The verdict on the extent of new legislation is still to be determined. 

Techniques/technologies used:

What tools, techniques, etc., were used:

     In order to gather information in an industry that is known for implementing a “handshake” approach to business, much of the information on the art and antiquities trade gathering was offline and came from primary source interviews.

     Other data was gathered from government sources, corroborated in one-on-one interviews, and other papers sourced from think tanks.

     Business data from larger businesses was mined from available databases. 

     Satellite imagery was corroborated where necessary.


How did I use this data: 

     To examine the information used to promote new anti-money laundering policy with how that information held up to fact checks and historical precedence. 

What was the hardest part of this project?

     The most difficult aspect of this process was remaining the only person in the field/industry/government who did not seem eager to take a side. Not everyone I worked with on this project appreciated my apperant “neutrality.” 

     The reason I became interested in the legislation I reported on was because this new financial crime legislation was passed in the United States to target antiquities dealers (and potentially art dealers) before any hard evidence was put forth to support the legislation. Instead, Congress determined that the Treasury would have one year to investigate the extent to which this new legislation should be implemented, even though it had already been passed. Furthermore, much of the data put forth by lobbyists in support of the legislation did not hold up to a fact check, and in other instances of “evidence” were nothing more than hyperbole. 

     I took on this project because there was no available tangible information for the new legislation to be based on. I set out to figure out how promoters of the legislation felt about the antiquities trade and why they wanted it passed. I also set out to record the concerns of a dwindling industry that believed it had been the subject of a witch hunt that has the potential to erase the industry forever. 

What can others learn from this project?

     Today, some popular news outlets have taken for granted that the stewardship of cultural property is nothing more than a derivative of colonialism. This could not be further from the truth. While this project outlines a brief history of this misconception, it also illustrates the extent to which scapegoating the trade in antiquities has become gradually normalized. As an industry, the free market stewardship of cultural property has been nearly exterminated. While this paper touches upon some of the ways this is taking place (including the fact that new legislation was implemented without a proper investigation first to justify the scope of said measures), it is primarily an attempt to extract the information that is available for scrutiny, and allow the (presumably) lay reader to determine for themself if the legislation is justified based on the information available alone; or if what is happening to the antiquities trade is a good case study for hyperbole becoming common consensus at the expense of a group of people.

Project links: