Archive:July 18, 2025

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Key Lessons: The Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat Assessment

Key Lessons: The Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat Assessment

By: Michael E. Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott

On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14 May 2025, which make AMPs and HVDs legally responsible for reporting sanctions breaches involving designated persons (DPs).

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