Bonhams and Christie’s say that they had done research on their pieces, but were hampered by Italian authorities’ refusal to make the photographic database available to auction houses: “While we have a careful due diligence process in all other respects we have no way, without the co-operation of the Carabinieri, of checking this particular database. This case illustrates why that co-operation would be helpful,” said a spokesperson for Christie’s. As for the Roman statue, it was put on display in a New York art fair last year – but failed to sell. The US authorities are hoping to return it to Italy.
For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.
"We had a sincere friendship," Rybolovlev says. The two families vacationed together, with the Rybolovlevs often treating the Rappos to trips on private airplanes and their yacht. When Elena gave birth to a second daughter, Tania was asked to be godmother. Meanwhile the Rappos escorted the Rybolovlevs as they began making the rounds, helping them get into an exclusive golf club and chaperoning them to society events. As the Rybolovlevs expanded their real estate empire internationally, Tania Rappo also introduced Rybolovlev to real estate brokers abroad (at his request, she says).
These funds, as they’re called in Russia, are operated by LLCs that transfer assets, take out loans, and can make a single large organization doing all sorts of questionable deals and making eyebrow-raising purchases when viewed as a single entity, into a web of seemingly unrelated organizations with very different agendas. With enough records to have to sift through, they can hide their affiliations for years, often in plain sight, just because the web is too tangled to really unravel without a very good reason to spend months parsing paperwork.
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.
At the same time, Trump partnered with a real estate developer called Bayrock, founded by Soviet-born Tevfik Ariv who set up office in Trump Tower. In 1999, Russian-born former gangster implicated in a Wall Street pump-and-dump scheme and money laundering, Felix Sater, joined Bayrock and would become a top Trump adviser. Sater claimed they would talk often, with him pitching ideas on a regular basis. By 2005, the duo is trying yet again to build a hotel in Moscow to no avail.
"We had a sincere friendship," Rybolovlev says. The two families vacationed together, with the Rybolovlevs often treating the Rappos to trips on private airplanes and their yacht. When Elena gave birth to a second daughter, Tania was asked to be godmother. Meanwhile the Rappos escorted the Rybolovlevs as they began making the rounds, helping them get into an exclusive golf club and chaperoning them to society events. As the Rybolovlevs expanded their real estate empire internationally, Tania Rappo also introduced Rybolovlev to real estate brokers abroad (at his request, she says).
The police also arrested Tania Rappo, a charismatic Monaco socialite whom officers interrupted in the middle of a massage. Once a member of Rybolovlev's inner circle, Rappo and her husband Olivier, a retired dentist, had dined with the tycoon and his parents only days before. Now facing charges of money laundering, she would later tell me over dinner how the oligarch had plied her with drink as they chatted in his penthouse.

The bank bought an $850 million stake in a Ukrainian steel mill through a mystery middleman, then sold it to Russian-Canadian investor Alexander Shaider. This investor who would then fund Trump International Hotel and Tower in Toronto, and pay the consulting and licensing fees to label it a Trump property and bring it under The Donald’s umbrella in the public eye. In fact, this is how Trump’s name ended up on so many buildings. It’s licensed while its true owners are out of sight, and out of mind.
"[If ] he would have asked me," she says, "I would have told him." The question echoing around the art world is how one of the world's richest, toughest investors—whose trusts own the penthouse at 15 Central Park West (bought for $88 million in 2012 and occupied by his daughter Ekaterina, a college student at the time); two entire Greek islands (Sparti and Skorpios, famous for hosting Jacqueline Kennedy's wedding to Aristotle Onassis); the Maison de l'Amitié (a Palm Beach mansion bought from Donald Trump for $95 million, which Rybolovlev reportedly intends to demolish due to mold problems); a $20 million property on Kauai bought from Will Smith; a $100 million yacht; homes in Gstaad, Geneva, Paris, and Monaco; and AS Monaco, the soccer team—could make himself so vulnerable. Was he, like many new billionaires, in such a hurry to build a glittering collection that he failed to "learn art," as experienced patrons know one must to avoid overpaying? The art market is often described as insider trading conducted by a small but sophisticated network of "experts" who prey upon the naïveté of the nouveau riche. Did Rybolovlev, a famously shrewd and strategic investor, underestimate its ability to confound and deceive? Until now he hadn't talked.
The King free ports, as the Swiss media have dubbed him, Bouvier was embroiled in a similar legal scandal in 2008, when he was connected to a group that tricked an aging collector into selling a piece by Russian-born French artist Chaim Soutine that was then flipped to the National Gallery of Art in Washington, DC. A suite filed by the heirs of Canadian Lorette Jolles Shefner claims she was misled into selling Piece of Beef for $1 million in the Spring of 2004 by two art experts who, a few months later, sold it to the National Gallery for nearly twice the price. Bouvier was "acting in concert [with the experts] to disguise the true ownership" of works of art as part of the fraudulent scheme, court documents revealed.
For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Well, I'd been on the run and was eventually arrested at my villa in Marbella.I knew one of the Italian godfathers of the mafia who also has a villa there. We are great friends. So within ten minutes of being arrested, his counsellor was in my cell. He said, "Felice cannot come but he sent you his kind regards," so then I was sent to Madrid where I dined with a very important member of the police. He arranged for me to go to prison there instead of being extradited to France where they were really after me. I had the best time of my life in jail [in Madrid]. I had the guarantee I was coming out in a year and I bought a cell phone from one of the ETA boys in there. It was like that movie Goodfellas. I had my own kitchen, my own shower, and every day I could bribe one of the guards to go to the market-it was fantastic.
Anonymity was certainly a factor in the success of the scam that took down the estimable Knoedler gallery in New York after 165 years in business. Some $80 million was turned over by collectors to purchase unknown, albeit fake, “masterpieces” that were brought to market by a Long Island art dealer and her boyfriend. They said all the work had come from a mystery collector who became known as Mr. X. In fact, they were being created by a forger in his Queens garage.
Rybolovlev, meanwhile, was only getting richer. In 2007 Uralkali floated on the London Stock Exchange and became the most successful Russian IPO ever. Less than a year later the Putin regime—which is notoriously antagonistic toward Russian oligarchs living abroad, particularly ones whose fortunes derive from buying post-Soviet assets on the cheap—summoned him to a meeting in Moscow,
To be greeted by a Russian-speaking security team at La Belle Epoque, Rybolovlev's Monaco residence (reportedly the most expensive apartment in the world, worth $323 million), is not a surprise, then. The three-story penthouse also happens to be the scene of Monaco's most infamous murder, that of the Lebanese-Brazilian banker Edmond Safra, who was killed in a botched arson attempt by one of his caretakers in 1999. British developers Nick and Christian Candy subsequently renovated the manse to resemble a modern Versailles. My heels click-clack on the marble floors as a pleasant but pale aide-de-camp ushers me into the living room, where Rybolovlev's young lawyer, Tetiana Bersheda, tall and thin, with diamonds around her neck and wrist, soon comes to fetch me.

The 2,200 photographs by masters like Alfred Stieglitz, Edward Weston and Edward Steichen — more than could fit into an 18-wheeler — were paid for, court papers say, with some of the $78 million that the authorities say Mr. Rivkin got from defrauding oil companies like Shell, Exxon, and Mobil. Mr. Rivkin, who has not been charged with any crimes, was last thought to be in Spain and had arranged to have the photos shipped there.

Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.


The cringeworthy part of the story is when the Times trots out the continuing battle between Yves Bouvier and Dimitry Rybolovlev to suggest malfeasance because Mr. Bouvier was allowed to sell a work for Mr. Rybolovlev but not pass the money through to his client. The joke here is that Rybolovlev, a Russian who lives in Monaco and banks in Cyprus while engaging is massive art deals and, separately, massive real estate deals, is a guy with the kind of profile that pops red flags in KYC reviews for more detailed review.
Some states have laws and ethical rules regarding solicitation and advertisement practices by attorneys and/or other professionals. The National Law Review is not a law firm nor is www.NatLawReview.com  intended to be  a referral service for attorneys and/or other professionals. The NLR does not wish, nor does it intend, to solicit the business of anyone or to refer anyone to an attorney or other professional.  NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us. 
JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Happy with my work, the next time he took me to Armenia. He was smuggling of course, and when we got there we had drinks with the chief of police. There was a big organization bringing in lots of pieces from Moscow and Leningrad. The Russians and the Armenians were like mafia clans. They were very well-organized and working together. From there we took a bunch of art and flew to Beirut-the customs there were in on the game. We paid them off. That was basically the first time I smuggled on a large scale.
The Salisbury attack has reopened questions about more than a dozen suspicious deaths of Russians in London in recent years, many of them linked to organised crime. Even before the attack on the Skripals, the relationship between Russian money in London and international crime came under renewed attention with the success of the BBC television series McMafia.
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.)
There are no accepted estimates on the amounts of money laundered through the art market, although the general belief is that it is enormous and expanding as regulations on other asset classes, from real estate to foreign exchange, tighten up everywhere. The International Monetary Fund estimated that "the amount available for laundering through the financial system" was worth 2.7 per cent of global gross domestic product in 2009 or $1.6-trillion (U.S.).
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?"
I'm not going to bullshit you. Single shipments from Russia were between one and three million, which in the 60s was a lot of money. And these were regular trips-twice a month. It was raining money so I made my base in Beirut. Moneywise Beirut was a free banking market, so you could exchange a million dollars completely open on the square and no one would ask any questions. Of course you had to play the cat and mouse game with Interpol.
Of course, certain countries already impose AML regulations on the art world. The European Union Commission issued its 5th Anti-Money Laundering Directive in June 2018, which must be implemented by Member States by January 2020, and which in part expands its coverage of “obliged entities” to persons trading in art, acting as intermediaries in the trade of art, or storing art in freeports, if the value of the transaction or a group of linked transactions equals €10,000 or more. In the United States, although the BSA already applies to dealers in precious metals, stones and jewels, and thereby requires them to file Suspicious Activity Reports and comply with other AML obligations, no such rules currently apply to U.S. dealers in art.

The Toulouse-Lautrec work, “Au Lit: Le Baiser,” consigned for sale at Sotheby’s in London in 2015, depicts two women embracing on a bed. The Swiss dealer who brought the work to Sotheby’s, Yves Bouvier, signed the standard paperwork surrounding such a sale, which requires the consignor to indicate he or she either owns the painting or is authorized to sell it. After the sale, he was given the proceeds.

"We had a sincere friendship," Rybolovlev says. The two families vacationed together, with the Rybolovlevs often treating the Rappos to trips on private airplanes and their yacht. When Elena gave birth to a second daughter, Tania was asked to be godmother. Meanwhile the Rappos escorted the Rybolovlevs as they began making the rounds, helping them get into an exclusive golf club and chaperoning them to society events. As the Rybolovlevs expanded their real estate empire internationally, Tania Rappo also introduced Rybolovlev to real estate brokers abroad (at his request, she says).


Though relations between the Republican and Democratic members of the intelligence committee remain contentious, they seem to have improved since Chairman Devin Nunes stepped aside from the investigation amidst a bizarre escapade, in which the White House appeared to be feeding Nunes claims of ethical lapses by the Obama administration in handling intelligence information.
Michel: Well, by the time I was 15 I had been kicked out of seven schools. I must have been ADHD or whatever, because I fucking hated school and was always looking to start something for myself. So I began importing cheap hippie coats from Istanbul. They were basically sheepskins turned inside out with some sleeves on them. I began selling them in this hashish bar in Holland. They sold like fucking hotcakes. So I was going up and down between Istanbul and Holland quite a lot. Business was going well, and I was eventually approached in Istanbul by a man named E.

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.

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.
Scott has lectured and presented extensively regarding cybersecurity and corporate espionage at numerous conferences around the globe. He has recently overseen the development of several cell phone detection tools used to enforce a “no cell phone policy” in correctional, law enforcement, and secured government facilities. He is regularly interviewed for leading national publications, and major network television stations including Fox, Bloomberg, Good Morning America, CNN, CCTV, CNBC, & MSNBC. He is the author of "Hacked Again" and writes, "In a modern digital world no one is safe from being hacked, not even a renown cybersecurity expert."
He hasn't given many interviews over the past six years, but I managed to track him down for a chat. After learning I did a bit of unlicensed boxing before becoming a journalist, Michel took a liking to me, as he is a fighter himself. He once had so many contracts on his head that Scotland Yard detectives allegedly placed bets on how long he had left to live before he was murdered by a hitman.
If the BSA is extended to apply to dealers in art and antinquities, FinCEN can expect a robust notice and comment period for the implementing regulations.  Further, when proposing such regulations, FinCEN might draw upon some existing AML guidelines for the art trade, including those from two not-for-profit groups — one independent, the other supported by industry.  We explore those guidelines in the rest of this post.
×