OFAC Art Transaction Advisory Signals Increased Scrutiny

Law360 (November 10, 2020, 4:46 PM EST) -- On Oct. 30, the U.S. Department of the Treasury's Office of Foreign Assets Control issued an advisory and guidance addressing sanctions that may be imposed in connection with high-value artwork transactions.[1] The advisory expresses OFAC's view that the market for artwork valued above $100,000 is particularly susceptible to abuse by sanctions targets seeking to mitigate or evade applicable sanctions,[2] and is ripe for OFAC enforcement actions.

Accordingly, the advisory urges art galleries, museums, private art collectors, auction companies, agents, brokers, and other participants in the artwork market to develop and implement safeguards that will help them avoid transactions with illicit actors....

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