These galleries hosted artwork produced at the Pyongyang based Mansudae Art Studio, an UN-designated entity. sanctions.Īnother report published in March 2020 by the UN North Korea Panel of Experts uncovered troubling galleries and exhibitions in Beijing and Hong Kong. Policies that Undermine Sanctions, found that both Arkady and Boris were linked to shell companies that had purchased high-value artwork. The final report, titled The Art Industry and U.S. Senate investigated Arkady and Boris Rotenberg, Russian oligarchs who were designated by the OFAC. In July 2020, the Permanent Committee on Investigations of the U.S. This prompted OFAC to revise It’s Frequently-Asked-Questions (FAQs), reminding members of the art community of their sanctions compliance requirements. In a pre-emptive attempt to safeguard assets ahead of his designation, Ahmad was found to have stored personal funds in high-value artwork. Ahmed as a top donor to the terrorist organization Hizballah. In 2019, OFAC designated Nazem Said Ahmed, a Lebanon-based diamond dealer and art collector, a Specially Designated Global Terrorist (SDGT). The advisory is the result of a series of prior enforcement actions and investigations that garnered mainstream media attention. The ACSS takes a deep dive into the advisory, pulling practical insights that are worthy of your consideration.Įxamples of Sanctions Evasion Using High-Value Artwork The document also provided guidance for implementing sanctions risk compliance strategies. The publication highlights high-profile sanctions evading transactions and vulnerabilities in the high-value artwork marketplace. Treasury’s Office of Foreign Asset Control (OFAC) highlights this continued focus.įollowing a number of investigations, OFAC issued the advisory, detailing the Potential Risks Arising from Dealings in High-Value Artwork. Nor does this mean that government authorities have lost sight of these vehicles from a regulatory standpoint. That is not to say, however, that traditional investment vehicles aren’t being used to circumvent government authorities. As of late, unconventional mediums of exchange and stores of value, such as cryptocurrencies, have been a focal point for governments looking to clamp down on money laundering, sanctions evasion, and other illicit financial activities.

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