The Art Market and AML Regulations: Dealer Survey
Welcome to the Center for Art Law Anti-Money Laundering Survey for art dealers and galleries (the "Survey"). We are developing a comparative guide to provide insights for members of the art trade and their council on the current state of implementation of the recent AML regulations. Members of the art trade operating in the United States, the United Kingdom and the European Union are invited to answer the following questions. (Approx. completion time = 5 mins)

The Center will publish its research findings in the Fall of 2021.*

If you would like to receive the results of the Survey or to be invited to related AML training opportunities, please subscribe to the Center's mailing list at https://itsartlaw.org/newsletter/

Thank you very much for your participation!

DEADLINE EXTENDED: Please complete this questionnaire by 11:59 EST, October 1, 2021.

* Excluding participants who wish to remain anonymous.
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Email *
Please provide the name and the primary place of business (e.g. Center for Art Law, New York City) : *
If applicable, please tell us where your business is based (please indicate if more than one country) : *
Required
Does your gallery have offices in multiple jurisdictions? *
What is your business structure/ type? *
Required
How would you describe your business? *
Required
If required, who in your company needs to register according to AML Regulations? *
Required
Are you a member of a professional dealer association (eg. BFADA; LAPADA; SLAD)? Please indicate Yes and the full name of the association, or No. *
Do you have a compliance officer in the gallery? *
Does your business have an in-house legal advisor? *
Do you have external legal counsel who acts as your compliance officer? *
Do you know what Anti-Money Laundering ("AML") legislation affects your business and how the regime applies to your practice in particular? If Yes, please detail below : *
If applicable, what is the general response from clients when asked for their ID documents? *
Very good (quickly compliant)
Not great (clients feel challenged)
If you have started conducting your due diligence, when did you begin? (If not applicable, include the date when you intend to start) *
MM
/
DD
/
YYYY
How have you informed clients of the new requirements/ processes and what must they do on their part to comply? *
Have you started conducting due diligence and KYC checks on your clients already (e.g. asking clients for ID documentation)? *
What have you done to prepare for AML implementation (e.g. invested in compliance arrangements)? *
Have you attended third party trainings on the subject of AML and KYC (e.g. Talking Galleries)? If Yes please detail below : *
What digital compliance solutions (if any) are you using? *
Do you deal in Non-Fungible Tokens (NFTs) of works of art? *
Do you accept cryptocurrencies (such as Bitcoin) as payment for art sales? *
How concerned are you about your local AML regulations and their impact on the art market? *
Very concerned
Feeling confident
How concerned are you about your local AML Regulations and their impact on your business? *
Very concerned
Feeling confident
What are your main concerns about the AML Regulations for your business? *
Where do you go for answers regarding legal obligations? *
Required
Do you know where to find more information and assistance on AML? *
Would you like to receive a written guide on AML in English or in the language(s) of the country where you are incorporated? *
Would you be interested in additional tutorial/ workshops to learn how to conduct KYC and AML work? *
May we publish the name of your business as a survey contributor in our research findings? *
Additional Comments (AML-related concerns or questions etc.)
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