OFAC Issues Sanctions Guidance for High-Value Art Industry
The Office of Foreign Assets Control issued a sanctions advisory and guidance on Oct. 30 about the risks associated with dealing in high-value works of art. The guidance outlines which art markets may present sanctions risks and urges galleries, museums,…
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agents, auctioneers and collectors to maintain a compliance program. OFAC also stressed that transactions involving expensive artwork are “not categorically exempt” from the Berman Amendment to the International Emergency Economic Powers Act and the Trading With the Enemy Act. The amendment “generally exempts” imports of art from IEEPA regulations, but OFAC said it does “not interpret this exemption to allow blocked persons or their facilitators to evade sanctions by exchanging financial assets such as cash, gold, or cryptocurrency for high-value artwork or vice versa.” OFAC said it will apply both IEEPA and TWEA sanctions on any art-related dealing involving a blocked person “to the extent the artwork functions primarily as an investment asset or medium of exchange.”