Attached are two responses (and our September 2020 report) to the September 23, 2021 Advanced Notice of Proposed Rulemaking (ANPRM 1506-AB50) by the Financial Crimes Enforcement Network (FinCEN), which is seeking to implement Section 6110 of the Anti-Money Laundering Act of 2020 (AML Act). Section 6110 of the AML Act amended the Bank Secrecy Act (BSA) by including, as a type of financial institution, a person engaged in the trade of antiquities, including an advisor, consultant, or any other person who engages as a business in the solicitation or the sale of antiquities. Section 6110 requires the Secretary of the Treasury to issue proposed rules to carry out the amendment. 

 The attached letters (one from the Financial Crime Task Force Chairs of the Antiquities Coalition; the other from the Coalition itself) comment on the range of questions related to the implementation of amendments to the Bank Secrecy Act (BSA) regarding the trade in antiquities presented in ANPRM 1506-AB50. The co-chairs of the Antiquities Coalition’s Financial Crimes Task Force build on the report from the Task Force, comprise by members with extensive experience in the AML/Sanctions/Counter Terror Finance (CFT) fields.

 The Antiquities Coalition unites a diverse group of experts in the fight against the illicit trade in ancient art and artifacts. In addition to championing better law, policy, and digital infrastructure, the AC fosters diplomatic cooperation and advances proven solutions with public and private partners worldwide, including the U.S. and foreign governments, law enforcement, archaeologists and the art and antiquities market and museum leaders.

 The letters were posted on Regulations.gov today at https://www.regulations.gov/comment/FINCEN-2021-0006-0038 and https://www.regulations.gov/comment/FINCEN-2021-0006-0034.