Let’s get back to the real estate pilot program that lies at the heart of the Times’s confusion. That federal program, which may or may not be continued, relies upon mortgage title insurance companies to report to authorities the ultimate beneficial owner of any vehicle used to buy or sell very valuable real estate. It does not require the seller to reveal the beneficial owner to the buyer or vice versa.
Bouvier, of course, denies all accusations, claiming to have found out about the complaint as he was arrested. An art market insider explained to Forbes that it’s common for intermediaries to take their cut directly from the selling price, which in most cases isn’t illegal, unless certain conditions are violated. Forbes reached out to three different lawyers connected with Bouvier (David Bitton, Luc Brossollet, and Charles Lecuyer) but wasn’t able to get a response.
Meanwhile, Trump was exploring a foray into reality TV about a St. Petersburg-based MMA fighter and his son, Donald Trump Jr., told the media that “Russians make up a disproportionate amount of Trump assets,” a claim his brother Eric would take even further in 2014 when he said that Trump has “all the money [he] needs from Russia” and cited golf-loving oligarchs investing over $100 million in the family business. Eric would later deny he ever said any such thing, playing into his father’s campaign against “the lying media and its fake news” when this story was dug up earlier this year by journalists.
If you think that it would be a major oversight to allow people to create plausible deniability just by setting up enough legal entities with limited liability between themselves and their partners, you would be correct. It’s actually illegal under the FCPA, or the Foreign Corrupt Practices Act, which requires basic due diligence prior to making any deals with foreign citizens or in other nations. Domestically, RICO (Racketeer Influenced and Corrupt Organizations Act) goes after opaque arrangements that hide crimes like tax evasion and money laundering to create plausible deniability.
After that I knew there were a lot of stolen Nok pieces that were going to be exhibited at a gallery in London-all worth around $400,000-sold to some of the wealthiest people in the world. I could've easily made a lot of money for myself by approaching the dealer and saying, "Give me 100 grand to keep my mouth shut about where they came from," and I would've gotten it in a nanosecond. But instead I went to the Nigerian embassy and convinced the ambassador there about these stolen Nok pieces.
Contact an art advisor to help you find a buyer for your work or see if an auction house like Sotheby’s or Christie’s wants to auction it for you. If they help you sell your collection, they will make money, so it’s in their best interest not to ask any questions. Make an appointment with an auction house to appraise the pieces in your collection. You’ll sign a contract that says you are allowing the auctioneers to sell your collection on consignment, which means if it sells you get paid, and if it doesn’t you get the art returned to you. It will also tell you what sort of fees you will be charged - like insurance, shipping, and the auction house’s cut. You’ll ship the work to the auction house, wait for your collection to be sold, and make it rain.

It is a very pretentious title, but yeah I was a big-time smuggler. I was very ambitious. It all started to get serious when I went to Russia after Beirut. In Russia the art smugglers all worked together so that they could have their claws in many different countries overseas. So if you were "in the game" and a promising prospect like I probably was and had contacts with one clan, you could have contacts with all the clans. I was involved in a big way because I knew all the people and could reach out to them. I could get to the countries behind the iron curtain. I was also dealing with VIPs. Don't think this was some kind of scumbag organization-we were dealing with people who were very high up on the political ladder. All you had to do was make sure everybody had his cut.
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In one current money-laundering case, United States authorities have accused Malaysian officials and associates in a civil complaint of converting billions of dollars of embezzled public funds into investments like real estate and art. Masterworks by Basquiat, Rothko, Van Gogh and others were purchased, many at Christie’s, according to a complaint filed by federal prosecutors. Later, a Cayman Island company owned by one of the accused launderers took out a $107 million loan from Sotheby’s in 2014 using some of those artworks as collateral, authorities say.
where Rybolovlev was informed that the Kremlin was reopening a potentially bankrupting investigation into the collapse of a mine belonging to Uralkali. Understanding the government's interest in his company and that his days of owning it were numbered, Rybolovlev cashed out, leaving his estimated net worth somewhere between $8 billion and $13 billion. He then focused on trolling the world for other investments. In 2010 he moved to Monaco, his trusts buying La Belle Epoque. His trusts also bought a majority stake in the AS Monaco soccer team in 2011. And in 2012 a broker recommended by Rappo sold his trusts the penthouse at 15 Central Park West. Rybolovlev says that Rappo called him as the deal was closing. "I've been offered a commission of $100,000," she told him. "Would you mind if I accepted?"
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Rantt Media’s comprehensive articles source reporting from top news organizations, but they’re also built on brilliant analysis from our team. We are independently-owned and strive for quality, not clicks. But the only way to truly have a media for the people is for media to be funded by the people. We take pride in being reader-funded so that we are beholden to you, not corporate interests. If you like the work we do, please consider supporting us by signing up for a monthly subscription.
Bouvier, of course, denies all accusations, claiming to have found out about the complaint as he was arrested. An art market insider explained to Forbes that it’s common for intermediaries to take their cut directly from the selling price, which in most cases isn’t illegal, unless certain conditions are violated. Forbes reached out to three different lawyers connected with Bouvier (David Bitton, Luc Brossollet, and Charles Lecuyer) but wasn’t able to get a response.
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So, with the help of a girlfriend who speaks better English, the potentate asked Heller, "What price did you sell it for?" The answer: $93 million, $25 million less than Rybolovlev's trusts had paid for it. Chuckling, Rybolovlev tells me his fellow diners at the Eden Rock "thought I was having a stroke." Less cheerfully he says it was the worst New Year's Eve of his life. Within minutes he was on the phone to Bersheda. For years, according to Rybolovlev, he believed he had been paying the middleman who had sold him the Modigliani (above)—as well as 37 other museum-worthy paintings—a commission of 2 percent (in other words, about $2 million for the Modigliani, not $25 million). He was now realizing every collector's worst fear: He had been fleeced, and the question was, for how long and how much?
Finally, he also failed to vet his partner in Trump Scion hotel opening soon in Dallas, who has deep ties in money laundering from Kazakhstan and Russia, and opened two offshores in Cyprus in 2008, which, again, is the favorite destination for Russian oligarchs’ exported cash. (The Scion deal ultimately fell apart due to public opposition to the project.)
Former Russian presidential placeholder, and current prime minister, Dmitry Medvedev could teach a master class in how these advanced schemes work. Using non-profits and LLCs run by his friends from law school, he was able to secure three massive compounds in Russia, a pair of yachts, run a secret mega-farm, an exclusive vineyard, turn an 18th century palace in his hometown of St. Petersburg into ultra-luxury condos, acquire a pair of yachts, and buy a castle and wine-making operation in Tuscany.

Rantt Media’s comprehensive articles source reporting from top news organizations, but they’re also built on brilliant analysis from our team. We are independently-owned and strive for quality, not clicks. But the only way to truly have a media for the people is for media to be funded by the people. We take pride in being reader-funded so that we are beholden to you, not corporate interests. If you like the work we do, please consider supporting us by signing up for a monthly subscription.

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The looting and illicit export of art treasures is not a new problem. It’s happened whenever there have been armed conflicts during which victorious troops plundered churches, temples and other buildings. Germany carried out massive looting in World War II. By the start of the 21st Century the trade in illicit antiquities had become so huge it was worth billions of dollars each year and was the biggest international crime outside drug and arms trafficking according to The New York Times. When a piece is stolen, the consequence for scholars is tragic, because essential information about the piece – where it was found, what else was with it – is lost forever.

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Rapid and dramatic rises—and collapses—in price are bad things for money laundering whose sole purpose is to find a relatively stable vehicle to mask the source of funds. Money launderers are not looking to make a profit on their purchases let alone a killing. In fact, a money launderer is willing to take a loss on the vehicle that hides the illicit source of the funds because that is the price of washing the money. If a money launderer buys something with dirty money that has the potential to be unsalable for clean money, it doesn’t work. Art, even some of the world’s best art, is often temporarily unsalable for a variety of real and legitimate reasons.
But while Simpson saw disturbing patterns, he was unable to nail anything down, because he couldn’t get the relevant records from banks and other financial institutions. Schiff posed an interesting question: Simpson didn’t have subpoena power, but the committee did. Who should it subpoena if it wanted to learn more? Simpson laid out a roadmap for Schiff:
Say you’re an oligarch in a country that loathes them but is powerless to do anything about their existence because the highest levels of government profit off their businesses, legal and not. While you might think you have it made, your position is actually quite precarious. Pull on your leash too much and start commenting on politics, and you might just find yourself in jail for tax evasion and embezzlement, or sent into exile according to the template that shut down a critical news channel first, and stealthily re-nationalized an oil empire soon after that.
When addressing the KYC procedures under Guideline 3, the AML Guidelines explain that establishing a client’s risk profile will require an art business to obtain information on the client; understand the purpose and intended nature of the transaction; and understand the client’s source of wealth and how they acquired their art collection.  The AML Guidelines also stress the need to identify beneficial ownership, “even if the contracting client raises confidentiality concerns,” and note that the art business “may also choose to include appropriate warranties and representations in their agreements with their clients to emphasise the importance of this point.”  Further, art businesses should peform due diligence on intermediaries, such as art advisors or brokers, acting for one of the parties to a transaction.
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