Susan Mumford and Chris King, co-founders of ArtAML, return to the Podcast and talk with Steve about the recent release by the Financial Crimes Enforcement Network ("FinCEN") of its “Study of the Facilitation of Money Laundering and the Financing of Terrorism through the Trade in Works of Art." To the surprise of Steve and his guests, FinCEN concluded that there is limited evidence of money laundering and little risk of terror financing through the sale of high value art. The discussion focuses on the findings of the study, and its implications, particularly when compared with the existing AML regulations covering the art market in the UK and the EU. (Susan and Chris discussed these requirements with Katie and Steve on the November 1, 2021 episode entitled: “How Anti-Money Laundering Regulations are Hitting the Art Market in the United Kingdom and What Participants Can Do to Comply.”)  Recorded just days after Russian troops invaded Ukraine, the conversation turned to the impact that sanctions against Russia and its oligarchs are likely to have on the high-value art market, and what art market participants must do to not run afoul of these sanctions.