Terrorist Financing Risks and the Illegal Trade in Cultural Property

In recommendations published earlier this year, FATF expressly takes into account the illegal cultural property trade. Its 2013 guidance report titled “National Money Laundering and Terrorist Financing Risk Assessment” describes categories that should be included when authorities assess terror funding and money laundering risks. The report lists illicit trafficking of cultural goods, counterfeiting of antiquities, and the illegal trade of antiquities. The report also identifies art and antique dealers and auction houses as businesses “that may be useful [to include] in building a list of the ML/TF vulnerabilities that can be exploited in regulated entities.”

FATF recommends that risk assessments focused on terrorist financing and money laundering “should ultimately allow public authorities to make a judgment on the levels of the risks and priorities for mitigating those risks.”

One policy response that authorities might consider is the adoption of record keeping laws that spotlight black market antiquities. Such laws would foster transparency, helping to separate the legal cultural property trade from the illegal trade and serving to identify potential ML/TF crimes. A proposal describing these laws can be found in “Spotlighting Black Market Antiquities with Record Keeping Laws.”