New frozen asset reporting requirements: What Art Market Participants need to know

November 27, 2025

The UK government has introduced important reforms to the financial sanctions framework, effective 14th May 2025. These changes broaden who must report sanctions-related information to the Office of Financial Sanctions Implementation (OFSI) – and, for the first time, Art Market Participants (AMPs) are formally included.

For the art market, the most significant development is the introduction of mandatory annual reporting of frozen assets. This closes a long-standing gap in sanctions compliance oversight and brings AMPs into line with financial institutions and other regulated sectors.

Annual reporting of frozen assets

The core change affecting AMPs is the introduction of an annual obligation to report any frozen assets they hold.

Frozen assets cover a wide range of financial or economic resources, including, for example, works of art that belong to an individual or entity on the UK sanctions list.

A key example of how this could apply to an AMP is if you have in your possession a work of art that is on consignment or has been sold – and the owner has become sanctioned while the object has been in your possession.

Key dates for 2025 and where to find forms

Valuation date: 30th September 2025
Submission deadline: 30 November 2025

If you hold frozen assets on the valuation date, you must report them to OFSI using the official template.

Where to find the forms:

The official reporting template and OFSI’s annual notice are available here (updated each year): https://www.gov.uk/government/publications/annual-frozen-asset-review-and-reporting-form

In conclusion

Non-compliance without reasonable excuse is now a regulatory offence and can result in penalties. But equally, the reforms acknowledge the central role cultural assets can play in sanctions evasion risks and aim to ensure proportionate safeguards.

At ArtAML™, we know that most art professionals are doing their best in an increasingly complex regulatory landscape. These requirements may feel new, but they do not have to be overwhelming. We’re here to help you understand what counts as a frozen asset, how to assess potential risk and how to complete OFSI reporting correctly and on time.

If you believe you may be holding a frozen asset or simply want reassurance, get in touch. Compliance doesn’t need to be daunting and we’re here to support you every step of the way.