Art Law co-chair Megan Noh is quoted in a new Artsy editorial where she discusses the impending rule-making process for the BSA amendment that impacts the art industry, as well as the use of escrow and wire confirmation protocols in art contracts. According to Artsy:

There is also the possibility that the Bank Secrecy Act, which requires a level of transparency and diligence in transactions over $10,000 to combat money laundering, could be amended to include art dealers who are not currently covered by the bill.

“Privacy [will be] a huge issue as the changes to the Bank Secrecy Act are expected to ‘roll out’ on a wider industry basis next year,” said Noh, adding that “the legislation does not itself address questions about how diligence should be conducted with respect to agents doing business on behalf of disclosed but unidentified principals; rather this issue may be addressed in the year-long rule-making process that the passage of the bill triggers.”

Read Noh's full commentary in the article linked below.