As representatives of art intermediaries, now considered as obliged entities, we wanted to encourage our membership to participate at the Public Consultation Questionnaire. We first tried to complete the questionnaire ourselves. However, that turned out to be extremely difficult if not impossible, without hiring a lawyer specialized in AML.
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As an alternative to completing the questionnaire we therefore submit this CINOA Policy Paper on the proposed AMLR as a means of raising the many important issues and concerns of the art market sector.

Click here to read our submission.