Key risk alert: Art market & high-value transactions – your legal duties to OFSI
24 June 2025
The Office of Financial Sanctions Implementation (OFSI) has issued a Threat Assessment Report warning that Art Market Participants (AMPs) and High Value Dealers (HVDs) are increasingly being used to evade UK sanctions. Read the report here.
While aimed at AMPs and HVDs, the risk of sanctions breaches is highly relevant to insolvency practitioners – particularly when dealing with estates, luxury assets, or cross-border cases.
Your legal duties – reporting to OFSI
Under the Sanctions and Anti-Money Laundering Act 2018, if you know or reasonably suspect that a person:
- Is a Designated Person (DP); or
- Has breached UK sanctions
You must report to OFSI as soon as practicable, where the knowledge arose in the course of business.
Reports must include:
- The facts or information leading to the suspicion;
- Any identifying details about the person;
- If the person is a customer and suspected DP, the nature and amount of funds or resources held.
New IPA guidance from 14 May 2025
The IPA has published updated reporting guidance for Insolvency Practitioners. Access the IPA guidance here.
Penalties for non-compliance
Failing to report is a criminal offence, punishable by:
- Up to 6 months’ imprisonment,
- A fine, or both.
OFSI can also impose civil penalties of up to £1 million or 50% of the value of funds involved, and may refer serious cases to the National Crime Agency.
Further reading: Financial sanctions enforcement and monetary penalties guidance – GOV.UK