From a US sanctions perspective, which is true of the high-value art market?

Sanctions and Compliance Domains highlight that the high-value art market is characterized by anonymity, confidentiality, private sales, intermediaries, and limited transparency. These conditions create vulnerabilities for sanctions evasion and illicit finance, including the possibility that sanctioned individuals may use art transactions to move value discreetly.

The Berman Amendment does not exempt high-value art transactions from OFAC regulations where value transfer is involved. OFAC has published guidance clearly stating that art transactions remain subject to sanctions rules. There is no value threshold such as USD 50,000 that determines compliance responsibilities.