From May 14, OFSI will take over the supervision of sanctions compliance in the art market. This change may seem confusing, but it doesn’t have to be complicated - a few small updates now will ensure you’re fully prepared.  
 
There are four key things you need to do before the the deadline:  
 
 
1. Know when you need to report sanctions information to OFSI
 
As you’ll remember from your Arcarta training, if you know that you have a relationship with a designated person (someone under sanctions), you must notify the sanctioning body as soon as possible.  
 
From May 14, 2025, this requirement expands—you must also report if you reasonably suspect that a party is sanctioned.  
 
You can [report sanctions breaches (or suspicions of them) here](https://www.gov.uk/guidance/suspected-breach-of-financial-sanctions-what-to-do).  
 
 
2. Turn on periodic checking within Arcarta
 
Sanctions lists change frequently—it’s critical to stay ahead of updates that could affect your client base. Arcarta can automatically check sanctions databases to ensure your clients haven’t been sanctioned since your business relationship began.  
 
For low-risk customers, we recommend setting up periodic checking every 12-months or whenever you next do business with that client. Higher-risk or regular clients may require checks more frequently.  
 
You can learn how to [enable periodic checking here](https://www.arcarta.com/university/periodic-checking-refreshing-reports).  
 
 
3. Update your risk assessments and AML policies
 
Your risk assessment and AML policy must always reflect your actual business practices. If you’re updating your approach to sanctions detection and reporting, these policy documents must reflect those changes.  
 
Regulators look out for inconsistencies. If your AML policy doesn’t accurately reflect your day-to-day processes, it could raise concerns during an intervention.  
 
 
4. Ensure your team’s AML training is up to date
 
We’ve updated the Arcarta training program to reflect these new OFSI obligations. It’s crucial that your whole team understands the changes and when they need to report sanctions information.  
 
If it’s been over a year since your last AML training, this could be the perfect time for a full refresher course.  
 
 
As with any regulatory change, the impact of these changes will vary depending on the type of work you sell and your client base. This article is for informational purposes only and does not constitute legal advice.‍

If you’d like tailored advice on how these updates affect your business, please be in touch - we’re happy to help.

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