Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/65

 used to purchase a piece of art, the Private Dealer responded that she did not. She explained that in the art industry, questioning the source of funds would be considered contrary to industry standards and norms at the time—although she has done it on occasion—and that art agents and intermediaries would not want to provide that information because of confidentiality and privacy concerns of both the art agents and intermediaries and their clients. She noted, however, that most of her clients are American and that she knows the identity of the ultimate buyer in the "majority" of her transactions.

The Private Dealer explained that over the years, her practices regarding AML have significantly changed, but since the art industry is not regulated in the United States, she has had to self-regulate, rely on the advice of lawyers with expertise in AML and other related areas, and look for potential red flags in transactions, including with respect to the provenance of art pieces, in addition to relying on her gut. To that end, she said that if something does not feel right, or she does not know someone personally or through their reputation, she will not do business with them.