As representatives of the art and antiques trade, CINOA supports effective measures against money laundering and terrorist financing and would like to work with the EU institutions to help provide information and insight into the art market sector and the sector’s business practices. CINOA believes that through further analysis and dialogues with all stakeholders, a workable policy can be defined properly pinpointing with whom, when and how new measures should be carried out.

Art dealers and art intermediaries have already for many years had to abide by the EU’s anti-money laundering rules concerning payments in cash, and art dealers are already obliged to report suspicions regarding possible illicit funding. We therefore suggest a cautious, proportionate approach to amending AML legislation. Unless a proportionate approach is adopted there is a risk of a reduction in sales of works of art, less promotion of works of art, ultimately leading to reduced interest for the preservation of heritage works and a loss of tangible movable culture.

This document explains our rationale for reducing the sector scope by implementing an increase in the transaction threshold used to define the in-scope sector. 

To download our complete submission, click here