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I don't think the mint prices for any works by shvembldr have ever exceeded €10k. I looked up the mint price for The Blocks of Art and it was 0.1eth (maybe $300 at the time), the closest I could find was the high point of an auction for Alien Insects was 3eth (~$9k at the time).

In addition to primary sales, there are also royalty payments for secondary sales but I don't think any of his pieces have ever sold for €200k (which would be required for a €10k royalty).

...but maybe this goes against the spirit of AML-D5 since popular generative art still drives many millions of dollars/euros in sales, but often split across smaller transactions (since a collection may contain hundred to thousands of individual pieces).

It seems like he took it out of coinbase in a lump sum, which resulted in a single large inexplicable transaction.

A transfer between your own accounts is pretty straightforward to declare, it's you on both sides.

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