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The Impact of the Corporate Transparency Act on the Art MarketThe Impact of the Corporate Transparency Act on the Art Market

Collectors and high-net-worth clients must comply with new requirements.

Georges Lederman, Special Counsel

March 18, 2024

11 Min Read
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As of Jan. 1, 2024, certain types of entities created in or registered to do business in the United States are required to report beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury. The Corporate Transparency Act (CTA), enacted in 2021 as part of the Anti-Money Laundering Act of 2020, imposes this new requirement in an effort to combat corruption, tax evasion, fraud, drug trafficking and the financing of terrorism. Although FinCEN hasn’t issued any specific regulations governing the art market, the CTA will nevertheless impact many entities that engage in art transactions as well as those that hold art as an asset class.

Although lawmakers may not have had...

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About the Author

Georges Lederman

Special Counsel, Withersworldwide

Georges is special counsel in the litigation and arbitration team.

Georges is an experienced white-collar defense attorney and former prosecutor who has focused on representing art world clients over the past 17 years. He has tried over 30 felony jury trials to verdict and has handled both criminal and civil matters that have received international media coverage.

For art market and other clients who have been under investigation by the Government, Georges has appeared before the New York County District Attorney’s Office; the United States Attorney’s Offices for the Southern and Eastern Districts of New York and the Eastern District of Pennsylvania; the New York State Attorney General’s Office; the Department of Homeland Security; United States Customs and Border Protection; United States Fish and Wildlife Service; New York State Department of Environmental Conservation; the IRS Criminal Investigation Division; the New York State Department of Taxation and Finance; and the Federal Deposit Insurance Corporation Office of Investigations.

Georges also represents collectors, art dealers, authenticators, galleries, museums, auction houses and luxury brand retailers in a wide range of civil matters involving title, provenance, authenticity, breach of contract and civil fraud. Georges advises these same clients as to compliance with federal and state government regulations involving the sale, transfer or other disposition of art and cultural assets.