UK Sanctions Enforcement: What the Government’s New Policy Paper Means for Art Market Participants

March 10, 2026

by ArtAML™ Team

The UK Government published its strategic approach to sanctions enforcement on 10th March 2026, bringing together civil and criminal enforcement responsibilities across HMRC, OFSI, OTSI, the NCA and others into a single framework. For Art Market Participants (AMPs), there are some clear take-aways.

Sanctions and AML are not the same

AMPs regulated under the Money Laundering Regulations 2017 are familiar with AML obligations: CDD, UBO verification, business-wide risk assessments, training and so on. Sanctions compliance is a separate and parallel obligation. It applies regardless of whether a transaction meets the €10,000 CDD threshold (soon to change to £10,000), and it entirely sits outside the MLR framework. The two overlap at the point of PEPs and sanctions screening during CDD, but sanctions obligations are broader than that.

Strict liability means that “I didn’t know” has limited value

Civil sanctions breaches are assessed on a strict liability basis. Enforcement authorities do not need to prove that an AMP knew they were dealing with a sanctioned person — only that the breach occurred. Inadequate screening is not a defence; it is an aggravating factor. Robust, documented compliance controls on the other hand are explicitly listed as a mitigating factor in the enforcement framework.

The enforcement net is joined up

The policy paper is explicit that cross-departmental working and referral processes for criminal enforcement are central to the government’s approach. As paragraph 10 of the paper states:

“A range of departments, agencies and regulators are responsible for the effective enforcement of UK sanctions and work closely to ensure a joined-up approach. The division of responsibilities and cross-departmental working includes referral processes for criminal enforcement.”

HMRC is the AML supervisor for AMPs and is actively conducting compliance interventions. Sanctions screening is among the questions HMRC asks during those visits. AMPs who cannot demonstrate how and when they screen are exposed — not just to a finding on sanctions, but to a referral upward into the broader enforcement framework.

What to do if you identify a sanctioned person

Do not proceed with the transaction. You are required to report to OFSI (for financial sanctions) and should also report to the NCA. Voluntary disclosure made promptly, before authorities become aware, is a significant mitigating factor under the enforcement framework.

How ArtAML™ supports your sanctions obligations

Since the Russian invasion of Ukraine in 2022, ArtAML™ has provided standalone sanctions screening as a freely available feature for all clients on a CDD plan. It can be used at any point, for any individual or company, regardless of whether a transaction falls within AML scope. You do not need to be processing a regulated transaction to run a screen.

Every screen is timestamped and recorded, giving you the documented audit trail that enforcement authorities expect to see. In a strict liability regime, evidence that you screened — and found nothing — is as important as the screen itself.

For more information about ArtAML™’s sanctions screening feature, get in touch.