OFAC Advisory and Guidance on Potential Sanctions Risks Arising from Dealings in High-Value Artwork

OFAC issued a formal advisory on October 30, 2020, warning art galleries, museums, auction houses, private collectors, and art dealers about sanctions risks when transacting in high-value artwork linked to blocked persons on the SDN List. The advisory described market characteristics — including opacity, use of intermediaries, and shell companies — that make high-value art transactions attractive vehicles for sanctions evasion.