OFSI guidance on sanctions implementation

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The Office of Financial Sanctions Implementation [OFSI] has released guidance on financial sanctions implementation for high value dealers, luxury goods markets and art market participants.

Guidance is provided for entities and individuals operating in the sale or trade of high value goods, especially those trading internationally with regions that may be subject to UK financial sanctions restrictions. It covers:

  • Asset freezes;
  • Circumvention typologies: the movement of assets, risks for high value dealers, and digital assets;
  • Reporting obligations;
  • Licensing;
  • Enforcement and penalties;
  • Ownership and control; and
  • Due diligence processes and best practice.

Relevant firms should read the new OFSI guidance, to ensure that their sanctions controls and policies comply with the recommendations.


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