Landmark Terrorism Financing Conviction Exposes Vulnerabilities in UK Art Market

Terrorist financing has long exploited both traditional financial systems and more opaque, high-value sectors—and a recent UK court case has brought the global art market into sharp focus. In April 2024, the British-Nigerian art dealer Ogeneochuko Ojiri was convicted at the Central Criminal Court (Old Bailey) for failing to disclose suspicious art transactions tied to Nazem Ahmad, a sanctioned Lebanese businessman accused of financing Hezbollah. This conviction marked the first time Section 21A of the Terrorism Act 2000—criminalizing the failure to report knowledge or suspicion of terrorist financing—was successfully used against someone in the art world.

Ojiri’s conviction set a legal precedent and revealed a critical intersection of financial crime, anti-money laundering (AML) compliance, and counter-terrorist financing (CTF) regulations within the art market. The case revolved around Ojiri’s role as a London-based art dealer who facilitated a series of high-value sales—totaling approximately £140,000—to Ahmad. Despite Ahmad’s designation on UK and US sanctions lists since 2019 for alleged links to Hezbollah financing, Ojiri completed the transactions without filing any Suspicious Activity Reports (SARs), as required by law.

According to the UK’s Crown Prosecution Service, Ojiri faced eight charges under Section 21A of the Terrorism Act 2000. Prosecutors established that Ojiri was aware of Ahmad’s status and took deliberate steps to obscure the buyer’s identity, including the use of aliases and altered invoices. His failure to report these red flags amounted to a clear violation of statutory obligations under UK AML and CTF laws. The court handed Ojiri a custodial sentence and ordered the seizure of artworks valued close to £1 million, including pieces by internationally acclaimed artists.

Section 21A of the Terrorism Act 2000 is aimed at ensuring that those in regulated sectors, including art dealers, report any knowledge or reasonable suspicion of terrorist financing. This provision, along with legislation such as the Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, forms the legal backbone of the UK’s effort to intercept illicit financial flows. As prosecutors emphasized, “Ignorance or selective blindness is no longer a viable defense.”

Ojiri’s prosecution confirmed the role that high-value dealers must play as gatekeepers in preventing terrorism-related finance. The case highlighted the art market’s susceptibility to abuse due to its reliance on high-value, easily transportable assets, frequently opaque transactions, and the use of intermediaries who may lack sufficient training or regulation. These conditions, when combined with a strong culture of confidentiality, create fertile ground for illicit finance.

In response to these systemic risks, the UK expanded its AML regime in January 2020 by including Art Market Participants (AMPs) as obliged entities under the Fifth Money Laundering Directive (5MLD), now embedded in UK law. This requires dealers handling transactions above €10,000 to perform due diligence, retain transaction records for five years, and submit SARs when needed. Ojiri’s failure to adhere to these obligations was central to the case. Prosecutors noted how he failed to perform proper checks, ignored red flags, and attempted to manipulate records—actions that not only enabled potentially illicit transactions but also subjected the broader market to significant regulatory risk.

The implications of this case reach beyond the art sector. Authorities successfully seized artworks tied to the offending transactions—underscoring that enforcement can extend to assets indirectly linked to terrorist financing. As one legal observer noted, “Effective enforcement is no longer limited to direct proceeds of crime; it now includes broader asset recovery where transactions show clear signs of criminal linkage.”

The outcome of this case holds urgent lessons for professionals in the art and luxury goods sectors. Dealers must implement comprehensive Know Your Customer (KYC) procedures, including identifying and verifying the identities of clients and the beneficial ownership of purchasing entities. Routine screening against sanctions lists and Politically Exposed Persons (PEP) databases is no longer optional. Any suspicion or reasonable grounds to suspect money laundering or terrorist financing must result in the immediate filing of a SAR with the UK’s National Crime Agency.

Equally important is the obligation to retain records and ensure documentation is not tampered with. The court heard that Ojiri attempted to conceal Ahmad’s involvement by using fake names and editing sales invoices—an act that exacerbated his legal exposure. In the words of the prosecutor, “This was not a case of ignorance. It was active concealment.”

Training and ongoing awareness among staff and intermediaries are critical. The art market’s reliance on agents and advisors makes it particularly vulnerable to regulatory breaches, especially where those actors are unaware of or untrained in AML obligations. Authorities like the UK’s Financial Conduct Authority (FCA), the National Crime Agency, and international bodies such as the Financial Action Task Force (FATF) offer detailed guidance, including red flag indicators specific to art and high-value goods markets.

This case is also a signpost for future regulatory and enforcement directions. As digital art platforms and cryptocurrency payments gain traction, new compliance risks and technological challenges emerge. Dealers must ensure their AML frameworks evolve alongside these developments, addressing vulnerabilities in online transactions and digital asset storage.

Meanwhile, authorities are expected to continue expanding international data-sharing and coordination efforts to intercept cross-border financing networks. With stricter enforcement regimes and enhanced legal powers, prosecutors will likely pursue more high-profile cases across traditionally opaque sectors.

The conviction of Ogeneochuko Ojiri marks a significant evolution in how governments are addressing terrorist financing in non-traditional sectors. The case sends a clear message: compliance with AML and CTF regulations is not merely administrative—it is a core defense mechanism in the global fight against terrorism.

As regulatory scrutiny deepens, businesses across the art and luxury goods sectors must shift from reactive to proactive. “The art market, often prized for its secrecy and exclusivity, must now become a bulwark against illicit finance,” concluded one legal analyst. “Vigilance, transparency, and a genuine commitment to the law will define the future of this sector.”

The consequences for those who ignore their obligations are no longer theoretical. As this landmark case shows, they are criminal.

By fLEXI tEAM