From May 2025, financial sanctions in the UK will apply to the art trade, imposing new compliance and reporting obligations.
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Who is Affected?
The new rules will apply to Art Market Participants dealing in high-value artworks (€10,000+), including dealers, auction houses, and galleries, and businesses already registered as High-Value Dealers.
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What Are the Obligations?
All businesses in the UK are already obliged to ensure that they do not engage in transactions with individuals or entities subject to UK financial sanctions (referred to as "designated persons"). The new obligations add additional responsibilities to;

- Report any suspicion or knowledge of dealings with designated persons to HM Treasury.

- In some instances, freeze assets if a designated person is involved.

- Halt transactions if a buyer or consignor is later identified as sanctioned.

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This builds on existing responsibilities under Anti-Money Laundering (AML) regulations and aligns with OFSI's oversight of sanctions across 35 regimes and over 3,800 designations.
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Risks of Non-Compliance
Failure to comply could result in penalties up to £1 million or 50% of the breach value, and prison sentences of up to seven years.
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This significant regulatory change was announced by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, for more information see the full guidance here.

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This is the first of our new series The Compliance Canvas keeping you up to date with the changing regulatory landscape. Art market journalist Riah Pryor will be breaking down key regulatory updates and their impact on the art world.

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