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Annual Frozen-Asset Reporting for Art Market Participants: What You Need to Know Each Year

Link to the most recent official forms:

https://www.gov.uk/government/publications/annual-frozen-asset-review-and-reporting-form 

Background - Why AMPs must now report:

In May 2025, AMPs were formally added as “relevant firms” under UK sanctions law, bringing the sector into scope for mandatory reporting of frozen assets.

This means that if an AMP holds an asset belonging to a sanctioned person — even if that asset is a work of art — they must report it to OFSI during the annual reporting cycle. The obligation applies regardless of business size, whether you are a sole-trading dealer or a major auction house.

Who must report:

Any UK person or business (including AMPs) holding frozen assets of a designated person must submit a report.

A “designated person” is any individual or entity listed on the UK sanctions list, including companies they own or control (50%+ ownership or effective control).

AMPs may encounter frozen assets where, for example:

  • Art is held on consignment
  • Funds are held from a sale or deposit
  • A client becomes sanctioned during an ongoing transaction

What counts as a frozen asset?

Sanctions law captures a broad range of “funds” and “economic resources”:

  • Funds: bank balances, cash, cheques, loans, financial instruments, cryptoassets
  • Economic resources: physical assets of value — including artworks, antiques, jewellery, vehicles, real estate, precious stones, and more

If the asset can be sold, traded, or used to obtain funds, it is likely to qualify.

Annual reporting cycle (same dates each year):

While specific dates may be updated annually by OFSI, the structure is consistent:

  1. Valuation date: Assets must be valued as of 30 September
  2. Submission deadline: Reports must be filed by 30 November
  3. Method: Using OFSI’s official spreadsheet template, submitted via email

These dates were confirmed for 2025 and have historically remained the same in previous years.

How to report:

Each year, OFSI publishes a refreshed reporting notice and downloadable template at the link above. The process typically requires you to:

  1. Download the latest template from gov.uk
  2. List all frozen assets held on the valuation date
  3. Submit the form via email to ofsi@hmtreasury.gov.uk
  4. Retain evidence, including a PDF copy of your completed template and OFSI’s acknowledgment

If you previously submitted a report but no longer hold frozen assets, you must submit a nil return. If you have never held such assets, you do not need to submit anything.

Practical tips for AMPs:

  • Keep client ownership information up to date. Sanctions designations can change unexpectedly.
  • Monitor the sanctions list regularly, especially for high-value consignments.
  • Flag long-term storage or consignment items for periodic review.
  • Document conversations and due-diligence steps — these records help if questions arise later.
  • Ask early. If you suspect an artwork may be owned or controlled by a sanctioned person, contact us promptly.

Support from ArtAML™: 

We know sanctions compliance can feel intimidating, especially for art professionals, most of whom are simply trying to do the right thing. Our goal is to make compliance clear, manageable, and proportionate.

If you identify (or suspect) frozen assets, or if you need help completing your annual return, our team is here to support our clients with practical guidance throughout the reporting cycle.

References: