OFAC Issues Advisory on Sanctions Risks Arising from High-Value Artwork Transactions

In many ways, the market for valuable art remains one that depends on long-standing relationships and a high degree of familiarity between market participants.  The importance of relationships in the art business makes sense.  One is more comfortable selling to or buying from a known quantity—someone whose values and ethics can be trusted, and someone with whom successful business has been transacted before.

As the market has globalized and as business has shifted first to art fairs and now online, however, the circle of relationships has widened and relationships have become less personal.  As a business matter, these developments have resulted in different kind of risk.  As a legal matter, these changes have brought about greater regulation and enhanced scrutiny on the art market.

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