To: All ATADA Members
From: Will Hughes, ATADA President
Our dedicated public servants in Washington, D.C. are again hard at work on legislation designed to burden small, art market businesses with damaging, costly and unnecessary regulation. A bi-partisan collection of strange bedfellows in the U.S. Senate introduced the “Art Market Integrity Act” on July 23, 2025.
The innocently named, yet grossly misguided bill, would force most art market participants to meet burdensome Anti-Money Laundering (AML) reporting requirements by setting thresholds for compliance as low as $10,000 per transaction or $50,000 in annual sales. Thus, even the smallest businesses and most part-time dealers would likely be subject to this proposed law. The Act would cover most participants in the art market, including, art and antiques dealers, advisors, auction houses, museums, custodians, and collectors.
U.S. art businesses, museums, and collectors will suffer significant harm and expense by the imposition of the same Federal reporting obligations on ordinary transactions as if they were financial institutions or casinos. Failure to meet these reporting requirements would expose art market businesses to draconian penalties. Most businesses would need to retain the services of AML consultants and to purchase AML software to ensure compliance.
One of the supporters of this misguided, and totally unnecessary legislation is the Antiquities Coalition. Yes, it’s the same organization that lobbied for the 2021 amendment to the Bank Secrecy Act that extended AML coverage to “antiquities” dealers. We are, thankfully, still awaiting the regulations that will define an antiquities dealer. Depending upon the ultimate definition of “antiquities”, many of our ATADA members will become subject to AML laws under that already passed amendment to the Bank Secrecy Act.
I’ve included a link to a good article on the proposed Art Market Integrity Act published in the Cultural Property News.
I would urge you to support the Cultural Property News as it is one of our only sources of timely and accurate information on cultural property issues and proposed legislation. As noted in the article, “the Art Market Integrity Act is Trojan horse, using the language of financial crime to pursue long advanced ideological goals aimed at eliminating the antiquities trade.” The foundation of the proposed Act rests on various false claims, misleading analogies, and a total disregard of the U.S. Treasury’s own findings with respect to money laundering and terrorist financing in the art market.
Time to get active! Contact your Senator (particularly if he happens to be one of the ill-informed sponsors of the proposed Act: John Fetterman, Chuck Grassley, Sheldon Whitehouse, Dave McCormick, Bill Cassidy and Andy Kim) and complain loudly about this misguided bill that will cause significant harm and incurred expense to small businesses. You could also decide to help support ATADA’s legal and lobbying efforts with your financial contribution. ATADA cannot have a significant impact in the legislative arena without adequate financial resources.
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