Compliance Perspectives

Katie Steiner on Compliance & Corporate Art Collections [Podcast]


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Post By: Adam Turteltaub

Most offices have art all around, generally of the not-so-special, bland, pre-printed poster kind. But many offices will have a few nicer pieces, whether it’s an oil painting, sculpture, mixed media work or perhaps some beautiful antiques to add a nice touch or spruce up the executive offices.

When you look at them, chances are you aren’t thinking of compliance risks, but in some cases you should. In this podcast Katie Steiner, attorney at the law firm Hahn Loeser & Parks, explains that acquiring art can be problematic if handled the wrong way. No organization wants to find out that the art on its walls was stolen, made from an endangered species or is a looted relic. Yet, it does happen.

To mitigate this risk she stresses that it is important to do your due diligence on the art. Take the time to make sure that someone is checking the provenance of the piece. An ownership history can provide reassurance that an ownership dispute is not likely to occur in the future, and that the piece is authentic and not a forgery.

Also, be mindful of the age of the piece. Generally speaking, newer art has less questions of provenance than older pieces

Ancient works of art, particular those made by traditional societies, often with religious meaning, may be subject to import restrictions in the United States. The 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property was adopted by the US. It limits import of objects from countries such as Cambodia and Syria. The State Department website lists several bilateral agreements that are in force.

Finally, be mindful of materials from endangered species, such as ivory and tortoise shell. These may be crafted into individual pieces or incorporated into antiques. Either way, it’s important to avoid violating any of the rules.

The bottom line is that corporate art doesn’t have to be limited to mass-produced posters. But, if your organization is investing in art, make sure that they are investing in a compliant manner.
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