The Art Industry and U.S. Policies that Undermine Sanctions/Section 5
V. CONCLUSION
As Congress and the Executive Branch consider ways to ensure the effectiveness of sanctions, the role that shell companies play in allowing UBOs to remain anonymous must be considered. While there are legitimate business reasons to retain confidentiality, offshore entities with nominee directors and shareholders pose a significant threat to the success of U.S. efforts to block sanctioned individuals from engaging in prohibited transactions.
The Subcommittee's investigation also makes clear that the voluntary programs in place at auction houses are not enough. Further, there is a lack of transparency in private art sales. As such, Congress should add high-value art to the list of industries that must comply with BSA requirements. Given the intrinsic secrecy of the art industry, it is clear that change is needed in this multi-billion-dollar industry.