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 from increased tourism. Fairs also expose current collectors to many different galleries and artists in one location, therefore avoiding the inconvenience of traveling between different locations. The 2019 Art Basel Miami Beach art fair, for example, hosted 269 galleries from 33 countries in the Miami Beach Convention Center.

E. Voluntary Anti-Money Laundering and Sanctions Programs in the Art Industry

As explained earlier, under current U.S. law, the art industry is not legally required to comply with the same anti-money laundering requirements as certain financial institutions listed in the BSA. The BSA authorizes the Treasury Secretary to require those financial institutions to file "certain reports or records. where they have a high degree of usefulness in criminal, tax, or regulatory investigations or proceedings, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism." In addition, the BSA states that "in order to guard against money laundering through financial institutions, each financial institution shall establish anti-money laundering programs, including, at a minimum—

the development of internal policies procedures, and controls; the designation of a compliance officer; an ongoing employee training program; and an independent audit function to test programs."

Although the provisions of the BSA do not apply to the art industry, all U.S. citizens and companies must comply with U.S. sanctions programs. Under IEEPA for example, any U.S. citizen or entity that conducts business with a person on the SDN list is subject to criminal and civil liability.