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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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