On March 12, 2025, the UK Office of Financial Sanctions Implementation issued updated sanctions guidance for individuals and entities engaged in the sale or trade of high value goods. The update provides that high value dealers, art market participants, insolvency practitioners, and firms (or sole practitioners) that carry out letting agency work will be added to the list of “relevant firms” subject to financial sanctions reporting requirements starting on May 14, 2025. OFSI also issued a fact sheet for high value dealers and art market participants, in particular, to provide them with a general overview of financial sanctions and to confirm the new reporting obligations. From May 14, 2025, these groups will be required to inform OFSI as soon as practicable if they know or have reason to suspect that person who is subject to UK sanctions has breached UK sanctions laws.
According to the fact sheet, the reporting obligations were expanded to include high value dealers and art market participants because of the high risk for exploitation in these sectors by those interested in evading UK sanctions. OFSI issued the updates to enable industry participants to combat sanctions evasion and implement policies and procedures that will enable them to comply with current sanctions regulations. For this purpose, both the updated guidance and the fact sheet contain common examples of sanctions evasion practices.
On March 12, 2025, OFSI also issued updated UK Financial Sanctions Frequently Asked Questions (FAQs 132 – 144) to address the new reporting obligations for these “relevant firms.” The FAQs also clarify what is within the scope of the reporting requirement; possible exemptions from reporting; and sanctions guidance specifically tailored for art market participants and high value dealers, insolvency practitioners, and letting agents.
Guidance – Financial sanctions guidance for High Value Dealers & Art Market Participants | High Value Dealers and Art Market Participants FACTSHEET | Guidance – UK Financial Sanctions FAQs