The June 2025 threat assessment, published by the UK’s Office of Financial Sanctions Implementation (OFSI), highlights critical sector vulnerabilities.

This overview distils the key changes, OFSI’s sector findings and actionable compliance strategies.

Since May 2025, these sectors are now classified as “relevant firms” and must report to OFSI when they know or suspect:

• A person or entity is subject to UK financial sanctions
• A breach of sanctions regulations has occurred

Key details by sector:

• HVDs: Must report suspicious activity involving cash payments of €10,000+ in high-value goods.
• AMPs: Required to exercise due diligence and report art transactions worth €10,000+.
• Letting agents: Obligations now extend to all property deals involving land letting for a month or more.
• Insolvency practitioners: Must assess all transactions for sanctions risks during insolvency proceedings.

Failure to comply can lead to significant financial penalties, criminal prosecution, and reputational damage.

OFSI identifies main vulnerabilities (especially for HVDs and AMPs):

• Complex ownership structures: Use of intricate corporate/trust arrangements to obscure ownership.
• Opaque transactions: Cash, crypto and routing through high-risk jurisdictions to hide activity.
• Valuation manipulation: Over- or undervaluing goods to conceal true worth.
• Enablers: Both professionals and non-professionals may facilitate sanctions evasion.

• Unclear or obscured asset ownership/provenance
• Reluctance to undergo due diligence or rushed transactions
• Payment structures designed to circumvent regulatory limits or involving sanctioned jurisdictions
• Transactions that deviate markedly from market values

Non-compliance risks fines up to £1 million or 50 per cent of the asset value, with more serious breaches referred for prosecution.

To remain compliant and resilient, businesses should:

• Strengthen due diligence: Scrutinise all transactions and run robust Know Your Customer checks.
• Establish a compliance programme: Create clear policies, monitoring systems, and reporting pathways.
• Train staff: Ensure ongoing training to identify risks and understand reporting duties.
• Monitor continuously: Subscribe to OFSI updates and monitor sector alerts.
• Report promptly: When suspicions arise, report immediately to OFSI to limit liability and demonstrate compliance.

To assist firms in navigating these new obligations, OFSI has developed a suite of resources, making compliance more accessible:

• Sector-specific guidance: Detailed guidelines tailored to HVDs, AMPs, letting agents, and insolvency practitioners outline good practices, risk mitigation, and reporting processes.
  • Guidance for HVDs and AMPs
  • Guidance for Letting Agents
  • Guidance for Insolvency Practitioners
• Frequently asked questions (FAQs): Comprehensive answers to common concerns include specific scenarios businesses may encounter and can be found here.
• Webinars: These on-demand sessions, such as the High Value Dealers & Art Market Participants  webinar, help clarify compliance steps and provide actionable insights and can be accessed here.
• Factsheets and workshops: Summarised information and practical training for building a robust compliance programme can be accessed here.
• OFSI’s threat assessment published in June 2025 can be found here.