OFSI factsheet guide on UK financial sanctions for high value dealers and art market participants
14/03/2025
From 14 May 2025, High Value Dealers and Art Market Participants are legally required to comply with reporting obligations in the UK
In advance of 14 May the Office of Financial Sanctions Implementation (OFSI) recently published a factsheet providing new guidance on UK financial sanctions for high value dealers and art market participants.
Here are the key points:
- What Financial Sanctions Are:
- Financial sanctions are measures put in place to achieve the UK’s foreign policy and national security objectives. They help prevent terrorism, nuclear proliferation, internal repression, and human rights abuses
- Sanctions can be
- Geographic (targeting specific countries) or
- Thematic (targeting specific activities or entities)
- Guidance for High Value Dealers and Art Market Participants:
- Common Evasion Practices: The guidance outlines common methods used to evade sanctions and emphasizes the importance of vigilance
- Due Diligence: It stresses the need for thorough due diligence to ensure compliance with sanctions regulations
- Reporting: Entities must report any suspected breaches of sanctions to OFSI
- Licensing: The guidance explains the licensing process for transactions that might otherwise be prohibited under sanctions
- Compliance and Penalties: It details the penalties for non-compliance and the importance of maintaining robust compliance systems
- Ownership and Control: The guidance highlights the need to understand the ownership and control structures of entities involved in transactions
This guidance is crucial for those operating in the luxury goods and art markets to ensure they are not inadvertently breaching financial sanctions.
References
[1] Financial sanctions guidance for High Value Dealers & Art Market ... https://www.gov.uk/government/publications/high-value-dealers-art-market-participants-guidance/financial-sanctions-guidance-for-high-value-dealers-art-market-participants
[2] High Value Dealers & Art Market Participants guidance - GOV.UK https://www.gov.uk/government/publications/high-value-dealers-art-market-participants-guidance
[3] HIGH VALUE DEALERS AND ART MARKET ARTICIPP ANTS FACTSHEET - GOV.UK https://assets.publishing.service.gov.uk/media/67d1a44ba005e6f9841a1d90/HVD-AMP_Factsheet_2025.pdf
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.