Jurisdiction(s):
United Kingdom

Beyond AML: UK counter-terrorist financing duties for art market participants, with Ojiri case lessons on Terrorism Act 2000 s 21A, SARs, sanctions screening, tipping-off and s 19 risks

Published on: 10 June 2025

Published by a Law360 reporter

Legal News

Article summary

Across sectors where high‑value, cross‑border transactions are commonplace, exposure to financial crime is pronounced. Specific hazards include the possibility that assets traded are stolen or were acquired with the proceeds of crime; that either buyer or seller is implicated in terrorist activity; or that the asset functions simply as a vehicle for money laundering or terrorist financing. Although anti‑money laundering (AML) controls—such as requirements to disclose suspicious activity—are now firmly embedded within many firms’ compliance procedures, the absence of parallel counter‑terrorist financing controls persists as a key weakness. There are important lessons to draw from Ojiri’s case.

Art sales lead to hot water

From October 2020 to December 2021, Ojiri is reported to have sold eight artworks, with a combined value of £140,000, to an individual alleged to be involved in terrorist financing. Although this individual was not personally designated under the UK sanctions regime until April 2023, he had been listed by US authorities in 2019 as a ‘special designated global terrorist’, thereby barring him from entering into transactions with US persons...

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