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OFSI guidance for HVDs and AMPs on sanctions reporting

22 November 2024

OFSI guidance for HVDs and AMPs on sanctions reporting

The Office of Financial Sanctions Implementation (OFSI) published new guidance for High Value Dealers (HVDs) and Art Market Participants (AMPs)

 

The guidance aims to improve sanctions reporting, ensure compliance, and tackle common sanctions evasion practices present across the sectors.

  • From 14 May 2025, HVDs and AMPs will be required to report any dealings with sanctioned individuals or entities, enhancing transparency across the sector;
  • The guidance highlights common evasion practices, such as asset transfers via shell companies or offshore accounts, and underscores the need for robust due diligence​;
  • Digital assets, including cryptocurrencies, are identified as presenting emerging risks, with firms urged to implement strong compliance measures to prevent their misuse; and
  • Firms must regularly update their sanctions compliance programmes and monitor the OFSI Consolidated List to avoid breaches​.

✅ Firms operating in the HVD and AMP sectors should review their financial sanctions frameworks to ensure compliance with new and forthcoming requirements.