UK OFSI High Value Dealer Guidance

Updated on: Mar 21, 2025

Latest Event


  • Mar. 18, 2025 Email Alert Service
  • On Mar. 18, 2025, UK OFSI confirmed that the link has been added to the new joint UK sanctions email alert service, in the financial sanctions guidance.

On Feb. 13, UK OFSI issued sanctions guidance for high value dealers.

  • UK OFSI published guidance for UK financial sanctions in relation to high value dealers.
  • For entities and individuals which operate in the sale or trade of high value goods, especially if trading internationally with regions subject to UK sanction restrictions.
  • High Value Dealers
  • High value dealer is the term used to describe businesses and sole traders that make or receive relevant cash payments of €10,000 or more in exchange for goods.
  • Includes when a customer deposits cash directly into a bank account or when they pay cash to third party for your benefit; dealers can sell, receive, trade in luxury goods.
  • luxury goods are considered to be superior to comparable substitutes in terms of design, quality, durability or performance and are often associated with certain brands whose names are preferred by those consumers with strong purchasing power.
  • The high value dealer guidance is also relevant to art market participants.
  • Nov. 2024 Updated Guidance
  • On Nov. 14, 2024, UK OFSI announced the publication of updated guidance on UK financial sanctions for high value dealers and art market participants.
  • Guidance on UK financial sanctions covers common evasion practices, due diligence, reporting, licensing, compliance and penalties, ownership and control.
  • From May 14, 2025, the relevant firms list subject to financial sanctions reporting requirements will be expanded to include high value dealers, art market participants.
  • Mar. 2025 New Section Amended
  • On Mar. 12, 2025, UK OFSI amended section 2.1 with clarification, factsheet added.
  • The factsheet provides information on complying with financial sanctions, methods of circumvention and reminds that, from May 14, 2025, high value dealers and art market participants are legally required to comply with reporting obligations in the UK.
  • Mar. 18, 2025 Email Alert Service
  • On Mar. 18, 2025, UK OFSI confirmed that the link has been added to the new joint UK sanctions email alert service, in the financial sanctions guidance.
Regulators
UK OFSI; UK Treasury
Entity Types
B/D; Bank; BS; Ins; Inv Co; MSB
Reference
Gd, PR, 3/18/2025; Gd, PR, 3/12/2025; Gd, PR, 11/14/2024; Gd, PR, 2/13/2024
Functions
AML; Anti-Bribery; Compliance; Financial; Legal; Operations; Reporting; Sanctions
Countries
United Kingdom; Cross-Border
Category
State
N/A
Products
Banking; Clearing; Commodities; Deposits; Fund Mgt; Insurance; Loan
Rule Type
Final
Regions
EMEA
Rule Date
Feb 13, 2024
Effective Date
May 14, 2025
Rule ID
201097
Linked to
N/A
Reg. Last Update
Mar 18, 2025
Report Section
AML & Enforcement