Sanctions threat assessment: OFSI issues Art Market Participant and High Value Dealers threat assessment

On 18 June 2025, HM Revenue and Customs and the Office of Financial Sanctions Implementation HM Treasury (“OFSI”) issued a threat assessment (the “Threat Assessment”) covering threats to financial sanctions compliance relevant to Art Market Participants (“AMPs”) and High Value Dealers (“HVDs”).

On 14 May 2025, AMPs and HVDs became ‘relevant firms’ (as defined in legislation) and are subject to financial sanctions reporting obligations.

What is the purpose of the Threat Assessment?

The Threat Assessment is to assist AMPs and HVDs in complying with their reporting obligations and financial sanctions more generally.

What are the reporting obligations?

Relevant firms (as defined in the UK regulations under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA 2018”) are required to inform OFSI as soon as practicable if they know or have reasonable cause to suspect that a person:

• Is a designated person
• Has committed a breach or failed to comply with an obligation under the UK regulations.

A relevant firm is only subject to the reporting obligation if it became aware of the information or other matter on which the knowledge of reasonable cause for suspicion is based, in the course of carrying out its business.

When reporting to OFSI, relevant firms must include:

• The information or other matter on which the knowledge or suspicions is based; and
• Any information the relevant firm holds about the person, by which they can be identified.

If the relevant firm knows or has reasonable case to suspect that a person is a Designated Person and that person is a customer of the relevant firm, it must also state the nature and amount or quantity of any funds or economic resources held by it for that customer.

Updated: 19 June 2025

How Gherson can assist

The Gherson team have years of experience advising on compliance matters, including sanctions. We regularly advise clients on sanctions laws and can assist companies develop policies and systems aimed at prevention of sanctions risks.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail or, alternatively, follow us on X, Facebook, Instagram or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025