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

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 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.