Newsletters (May/June 2018 CINOA Newsletter)



Dear Colleagues,
I want to thank all of the members that have made the effort to write to their MEPs concerning the proposed legislation regarding cultural goods and money laundering. We have a Sisyphean task in front of us and, as everyone knows, it isn't the labor of pushing the rock up hill, it is the repetition that leads to ennui and, ultimately, apathy. We need to work at making ourselves into a community, one that is respected by law makers, a community that wishes to be a responsible actor in a turbulent world.
Crying wolf won't get any of us anywhere, but developing a system that keeps us alert and ready to act should encourage the recognition that CINOA needs to be taken seriously whenever an issue arises. This is an existential crisis that is happening in slow motion. Make no mistake that it is happening--we are, as seen by regulators--unregulated and ripe for regulation. If we aren't in on the decisions that will be made, we may find ourselves in the position of Prometheus without the possibility of being unbound.
For more information on our campaigns and to be informed on a more timely basis, join CINOA’s mailing list which will focus on legislation as the CINOA e-Newsletter will now be bimonthly. For more details please see the section below the fair announcements.
All the best,
Clinton Howell
President of CINOA


As you will know, CINOA has been taking a much more active role in recent months to influence international policy.

We have now retained the services of the Brussels-based public affairs consultancy Lighthouse Europe, which specialises in European strategy, to advise us and ensure that our concerns about the proposed legislation are heard. In particular, we have been addressing the crucial issue of proposed legislation on the import of cultural goods to the European Union and the proposed amendments to the EU Anti-Money Laundering legislation. Although EU proposals, these will have an impact on all global markets that do business with EU member states. CINOA Position papers are posted on the CINOA website in the section ‘Perspectives’
Please contact Erika Bochereau,, regarding any or all of the above.

EU Import of Cultural goods proposal

CINOA, in collaboration with the ADA and IADAA, continues its campaign related to the proposed legislation on the import of cultural goods to the EU. After initial contacts and discussions prior to the first committee reports, in April a CINOA position paper and proposed amendments was sent to all the MEP’s on the committees reviewing the proposal. (available on the CINOA website). We are now again meeting with MEPs staff members. We are encourage that the rapporteurs and MEPs are listening to our arguments but some are still convinced that there must be much stricter legislation. It is imperative that we continue to work to voice our concerns and work with legislators so that they have a better understanding of the art and antiques trade.

Anti-Money Laundering legislation

CINOA, along with members from Austria, the UK, Czech Republic, Spain, Netherlands, Finland and Sweden, campaigned by very actively contacting committee members and MEPs up until the day before the vote to get our concerns well known and influence the vote. Although we did get some sympathy and some support, we were not able to convince lawmakers to change the proposed legislation. However, we did make some important contacts that will be useful in the future.

The EU directive, which come into force in 2019, will cover all businesses selling works of art with transactions of €10,000 or more, irrespective of the payment method (credit card, bank transfer, cheque or cash), compelling traders in the EU to verify the identity of customers before making a transaction. Lower-value linked payments adding up to €10,000 or more will also now be covered. The existing regulations apply to any business trading in goods or making transactions of €10,000 or more in cash. This directive must be adopted EU member states so it is still very important that we continue to our efforts.

The US House Financial Services Committee is considering legislation that would add “dealers of art and antiquities” to the list of regulated financial institutions under the Bank Secrecy Act (BSA).

These developments are being monitored closely. We will provide more details to those interested. CINOA will support any efforts it can in the campaign to educate legislators and voice dealers concerns.

UK Ivory Ban update

The UK Government announced recently the results of its ivory consultation and its proposals for how it would wish to introduce the ban and the exemptions associated with it.

The Government's starting point was a manifesto pledge for an unqualified ban on all ivory, however their latest proposals do acknowledge a special place for cultural objects by granting a number of exemptions.  Whilst the Government has inserted an additional exemption (portrait miniatures), two of the proposed exemptions are more restrictive than was envisaged by the wording in the Government's consultation document and by the trade bodies in their various submissions.

Government proposals

The proposed exemptions from a ban are as follows:

*         Items with only a small amount of ivory in them. Such items should be comprised of less than 10% ivory by volume and have been made prior to 1947.

*         Musical instruments. These should have an ivory content of less than 20% and have been made prior to 1975 (when Asian elephants were added to CITES).

*         Rarest and most important items of their type. Such items should be made at least 100 years prior to the ban coming into force.

*         A specific exemption for portrait miniatures painted on thin slivers of ivory and which are at least 100 years old.

*         Commercial activities to, and between, museums which are accredited by Arts Council England, the Welsh Government, Museums and Galleries Scotland or the Northern Ireland Museums Council in the UK, or the International Council of Museums for museums outside the UK (and museums will be also able to purchase items not covered by the other exemptions).

The trade believes that the de minimis needs to be increased, and at the very least brought into line at 20% - it would be interesting to see the evidence the Government has to justify such a low threshold and to know why 20% is acceptable for musical instruments, but not for other cultural goods.

The UK dealers strongly believe there is a case for improvements to be made to the proposals because the exemptions now appear tighter than is required to achieve the aim of stopping the illicit trade in their ivory.

Invitation to the Authentication in Art 2018 Congress
(AiA)- June 7-9

Registration is still open for the Authentication in Art 2018 Congress (AiA) entitled, “Towards Solutions,” to be held 7-9 June 2018 in The Hague, Netherlands. The AiA Congress 2018 will focus on: *Connoisseurship, Technical Art History and Guidelines, Art & Law, Material Science, Artificial Intelligence and Authenticity issues: case studies.*

Authentication in Art (AiA) comprises a group of prominent art world professionals who joined together to create a forum that can act to catalyze and promote best practices in art authentication. AiA has been created to provide leadership and shape dialogue, develop sound practice guidelines with the worldwide art community including collectors, art historians, art market professionals, financial institutions, legal advisers, trust & estate practitioners and other stakeholders in the art industry.

The AiA Congress program:

Special attention will be for TAHDa: the Technical Art Historical Database. To learn more, watch the promo:

The AiA Congress Registration:

Please do not hesitate to contact Milko den Leeuw <> or Oliver Spapens<> with any questions or special requests.

Dear CINOA Dealer,

RubyLUX is proud to partner with CINOA. This partnership aims to advance the art and antiques industry by providing you with the exceptional online tools that RubyLUX has built to increase your business, and will continue to grow. We believe that you are the only one who can decide what is right for your business. Please browse through the site and contact with any questions.

Best regards,
NOTE: All the information in this newsletter is published in good faith and for general information purposes only. The information is not advice, and should not be treated as such. Please note that most excerpts come from the original publication and any credit must go to the author of the publication, not to CINOA. Any views or opinions expressed in the excerpts and/or articles belong solely to the author of the publication.

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