UK updates sanctions guidance for high value dealers and art market participants
High value dealers must use the UK Sanctions List and £10,000 threshold
Change
The UK government updated financial sanctions guidance for high value dealers and art market participants, changing the transaction-value reference to £10,000 and confirming the UK Sanctions List as the only source for UK sanctions designations.
Why it matters
The update changes the sanctions-screening reference point for high value dealers and art market participants. Compliance workflows must use the UK Sanctions List rather than the closed OFSI Consolidated List, and apply the £10,000 transaction-value threshold in the guidance. The added joint sanctions e-alert service gives firms a new route for receiving designation and sanctions updates.
Implications
- — High value dealers’ compliance teams must apply the £10,000 transaction-value threshold in sanctions controls — using the prior 10,000-euro reference conflicts with the updated guidance.
- — Art market participants’ compliance teams must use the UK Sanctions List as the source for UK sanctions designations — the OFSI Consolidated List is no longer the source of record after its closure.
- — Sanctions list-management teams supporting high value dealers and art market participants must update source references and alert subscriptions — stale OFSI Consolidated List workflows no longer match the updated UK guidance.
Who is affected
- — High value dealers’ compliance teams
- — Art market participants’ compliance teams
- — Sanctions list-management teams supporting HVD and art-market workflows