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Due Diligence Challenges in the Art Market and the Impact of Anti-Money Laundering Requirements

(252 reviews)

Produced on April 16, 2018

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Course Information

Time 1h 35m
Difficulty Intermediate
Topics covered in this course: Arts & Entertainment

Course Description

Traditionally, art market practices are typified by a high degree of tolerance for confidentiality and informality. These are perpetual challenges when performing due diligence and allocating contractual responsibility for warranties and representations.  These traditions are also problematic in the context of recurring demands for transparency, and concerns that legitimate customs and practices of the industry can be exploited for improper purposes such as money laundering. To what degree are art market participants subject to ever-increasing anti-money laundering (AML) regulations? What are the areas of conflict between AML requirements and art market customs and practices? This program, presented by Valentino Vasi and Judith Wallace of Carter Ledyard & Millburn LLP, will review recent art industry guidance on recommended AML and transparency best practices, and discuss how they can be implemented and benefit art market participants. 

Learning Objectives:
  1. Discuss areas of conflict between AML requirements and art market customs and practices
  2. Review recent art industry guidance on AML and transparency best practices
  3. Develop best practices for implementing this guidance, and examine how to best benefit art market participants

Credit Information

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Valentino Vasi

Carter Ledyard & Millburn LLP

Valentino Vasi focuses on compliance, regulatory, and legal issues for financial services firms, including broker-dealers and investment advisers. Mr. Vasi has more than 20 years of experience practicing corporate and securities law. This has included drafting, negotiating and interpreting contracts; counseling clients on relevant laws and rules; representing clients with regulatory agencies; and developing compliance programs for broker-dealers, investment advisers, mutual funds and hedge funds. He has held senior in-house positions with investment advisers, broker-dealers and money managers where he was responsible for establishing, instituting and administering effective state, federal, and regulatory compliance programs.

Mr. Vasi’s areas of responsibility have included advising about preparation and marketing of equity research, trade execution, investment banking, marketing and distribution of mutual funds, operation of separately managed advisory accounts and other investment advisory services, private fund formation, back office operations, formation and registration of broker-dealers and investment advisers, anti-money laundering compliance, review of marketing material, branch office inspections, and due diligence audits. He has been responsible for drafting policies and procedures for all of these activities and for management of regulatory examinations.

Some of his specific assignments included organization and implementation of cybersecurity programs, including asset and risk analysis and drafting of written policies and incident response plans, advising private equity firms on investment adviser regulation, analyzing international customer identification and Anti-Money Laundering regulations, and advising clients on how to improve new account intake processes around the world. His experience includes identifying potential compliance vulnerability and risk areas, developing and implementing corrective action plans to resolve issues, and establishing processes to avoid future problems.

Mr. Vasi is a member of the firm’s Cybersecurity practice, working with cross-functional group of attorneys to provide clients with advice on developing, strengthening, testing, and enforcing their information protection policies and procedures.

Judith Wallace

Carter Ledyard & Milburn LLP

Judith Wallace practices in the areas of Art Law, Environmental Law, Litigation and Energy Project Development and Finance. Ms. Wallace’s practice includes representing collectors, foundations, artists and scholars in matters of art ownership, authenticity, authorship, consignment and sales, foundation governance and other art-related matters; advising public agencies and private parties on permitting and compliance under state and federal environmental laws; and litigating art, environmental and general commercial matters in state and federal courts. She has been recognized by Super Lawyers® since 2012.


Peter O.

A fun, thoughtful course!

Wendy O.

Interesting info but could improve on presentation skills.

Henry G.

Excellent course with extremely engaging and knowledgeable speakers.


Vdery entertaining-had no idea these issues existed! Next sequel course-ONLY actual cases, with actual art works on slides. Thank u!

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