Art Market Participants: OFSI Sanctions Reporting Threshold Set in Pounds Sterling — Effective Immediately

A GBP threshold for Art market participants’ mandatory reporting obligations to the Office of Financial Sanctions Implementation is now in effect

The UK Sanctions Regulations have been amended to change from a Euro threshold to a GB Pound one. Art Market Participants became “relevant firms” in May 2025 and subject to mandatory reporting to the Office of Financial Sanctions Implementation. OFSI Guidance explains that the reporting duties apply in relation to the purchase, sale or storage of works of art where the total value of the transaction(s) reaches the “regulatory threshold” level. Until now, that threshold was expressed in Euros, it has been converted to pounds. These reporting obligations are in addition to existing suspicious activity reporting obligations on Art Market Participants under the UK Money Laundering Regulations and the Proceeds of Crime Act. 

Why has this changed?

 The change is made to align with the expected change to the threshold for Art Market Participants under the Money Laundering Regulations. The Euro thresholds are a “hangover” from the UK’s European Union membership. We expect that in the coming days or weeks the ML Regulatory threshold will be aligned to the £10,000 figure. This consistent figure will avoid having AMPs reporting under two different currencies. It is a harmonisation measure, not a tightening or loosening of the underlying threshold.

What do you need to do?

Amend internal documents, notices, terms, invoices and contracts to reflect the new currency threshold for mandatory sanctions reporting.   

Prepare for the coming amendment to the UK ML Regulatory figure from Euros to Pounds as well. 

Given current exchange rates, the switch to pounds from euros represents a modest reduction in the sterling value of the trigger point — but the practical implications will depend on how your firm has been applying the threshold in practice.

These types of changes should also be reflected in your annually required Risk Assessment. 

Remember OFSI’s 2025 Shot Across the Bow to the Art Market

OFSI have specifically warned AMPs that they have submitted “significantly fewer” than expected suspected breach reports. This expectation is based on scores of reports from bankers and lawyers. One can surmise that the bankers and lawyers working with various AMPs are submitting these reports and OFSI has noticed that the AMPs are not.  

To avoid exposure, please be sure to check that parties to your transactions and for whom you are storing works are not on 

1. the Designated persons lists; 
2. a company owned more than 50% by such parties or 
3. associated with sanctioned countries/ regimes

FCS Compliance helps art market participants meet their AML and sanctions obligations. Contact us if you have questions about this change.