Los Angeles-based editor of Politech, ex-Soviet computer lobotomist. Specializes in, but not limited to, science, AI, the web, conspiracy theories, and statistics. His work has been featured in or mentioned by How Stuff Works, BusinessWeek, Discovery News/Seeker, The Shift With Drex, Le Monde, SEED, Bad Astronomy, Science To The People, i09, and RawStory, among others.
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.
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.
Morland came out to find most of his profits had been lost. His old friends shunned him and the family firm went bust. So for the next thirty years he became a professional yachtsman-smuggler, plying his trade across the Mediterranean, shifting tons of hash, mixing with everyone from Berber tribesmen to gangland heavies, and alternating between periods of sudden wealth and bleak incarceration. In 1980, 1990 and again in 2000, he was caught and jailed for long terms. Now in his early eighties, he lives in “pretty good poverty” and teaches pottery. This is his amazing story.
Open a foreign bank account in a tax haven like Switzerland or the Cayman Islands. Banks in these countries are not required by law to hand over information about your account to anyone without your consent. If you open what's called a “numbered account” in a private Swiss bank like Union Bank of Switzerland or Credit Suisse Group, a number or code name will be associated with the account, rather than your name. To open a numbered account, you will most likely need to travel to Switzerland to do it, though if this is impossible, there are firms that help people set up off-shore bank accounts that can help you. You will most likely need to make an initial deposit of at least $100,000 to open the account, which will cost roughly $300 a year to maintain.
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“I've felt all along in the Russia investigation that the most important issues were those that had the potential of exerting a continuing influence over the administration and over U.S. policy,” Representative Adam Schiff of California, the ranking Democrat on the House Intelligence Committee, told me Friday. “And if the Russians were laundering money through the Trump Organization, the Russians would know it, the president would know it, and that could be very powerful leverage.”
"To put the mother of your two children in prison just not to give her money—what kind of person is that?" Rappo says. "This is the style of Mr. Rybolovlev, and that's exactly what happened to us. He wants to humiliate people and put such stress on them that they give up." (Rybolovlev brushes all this off and says Elena cannot stand to hear Tania Rappo's name.) I put it to Rappo: Why would Rybolovlev target her and Bouvier if not for the money he says they owe him?
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Finally, under Guideline 6, the AML Guidelines provides that art businesses must maintain adequate records of their due diligence efforts. Perhaps stating the obvious, but perhaps also implicitly acknowledging the existence of practices by certain dealers, the AML Guidelines observe that “[a]ll documents issued by an Art Business in connection with a transaction (e.g. valuations, sale and purchase agreements, invoices, shipping documents, import / export declarations etc.) should be true, accurate and contemporaneous and represent the honestly held professional opinions of the Art Business.” Likewise, dealers “should refuse all requests from clients to alter, back date, falsify or otherwise provide incomplete or misleading documentation or information relating to a transaction. If there are legitimate reasons for altering a document (e.g. invoicing error etc.) the circumstances and justification should be fully documented and retained on file for future reference and audit.”
Most of the billions vanished into a twilight world of offshore companies. The scheme cleverly mingled fake transactions with real ones. Some of it was spent on luxury items: furs, diamonds, Swiss watches, German industrial equipment, fashionable children’s clothes, plus hotel suites in Alpine ski resorts used by Russian oligarchs. It also went to a pro-Kremlin thinktank in Poland.
Still swirling around the market are persistent rumours that there is even more to the treasure than the known 14 pieces. Archaeologists claim that such finds always include spoons and coins, which were missing when the pieces started coming onto the market. Many believe they are still languishing in Swiss bank vaults, with the owner(s) waiting for the provenance issues to be cleared up entirely. It is to be ardently hoped that one day the whole hoard, in all its magnificence, will be returned to Hungary to be displayed together once again.
Sotheby’s declined to comment on whether it believed Mr. Bouvier to be the owner. But it says it knew him very well as a customer and that he had represented to them that he had the legal right to sell the property. As to its policy of learning the identity of ultimate owners, Sotheby’s said it takes a risk-based approach — sometimes requiring disclosure depending on the specific facts and circumstances of each situation.
What happened afterward is important, because whatever their disagreements, Rybolovlev and Bouvier agree that the nature of their relationship—whether Bouvier was an agent working for Rybolovlev on a commission basis or an independent art dealer who bought and sold works for himself, freeing him to charge any markup he liked—was never codified on paper. Rappo says that shortly after their encounter at the Geneva free port, Bouvier called her to ask her to arrange a follow-up meeting.
Over the years Bouvier has shifted his core business from art transportation to building and operating vast, secretive high-tech fortresses used for storing not just artworks but cars, wine, coins, and furniture. Such repositories, known as free ports, have existed for centuries, but until quite recently their primary purpose was to hold raw materials in transit—a shipment of soybeans, say. They were found primarily in transit zones, such as airports and canals, and they usually enjoyed one of the benefits of existence at the jurisdictional margins: tax and duty freedom.
In fact Trump named Wilbur Ross, the former vice-chairman of the Bank of Cyprus, as his commerce secretary. That bank was involved in deals involving Putin’s inner circle in 2015, and incidentally, Rybolovlev had a 9.9% stake in the bank until 2013, after which he divested for undisclosed reasons. It’s very possible that Ross actually has no role in any of this as former employees say he actually drove Russian oligarchs from the bank over his tenure, and the offshores were only used for a failed bid to build a casino.

The AML Standards for Art Market Operators (“AML Standards”) are set forth by the Basel Institute on Governance, an independent not-for-profit organization.  Not surprisingly, the AML Standards adopt a “risk based” approach to establishing measures to mitigate money laundering risks, and further note that “[s]mall businesses may not have the resources to address money-laundering risks in the same way that large auction houses or major dealers and galleries will have, and may have a different risk exposure.”  The AML Standards are intended to apply to everone trading in art objects, and intermediaries between buyers and sellers.  They also suggest that service industries supprting the trade in art objects that are already subject to AML laws, like financial institutions, should identify their clients and customers in the art trade “as higher risk as long as there are no internationally applicable standards.”
The data also shows payments to talent agencies, in London and California. The Laundromat was used to book artists on tours of Russia. They include the Florida rock band the Red Jumpsuit Apparatus and Israeli singer-songwriter Yoav. Both played in Moscow and St Petersburg in the autumn of 2013. There is no suggestion the artists were aware of the scheme.

Bouvier's plans were ambitious indeed. After the 2008 financial crisis, the Obama administration launched an attack on banking secrecy laws around the world, leading to an exodus of foreign cash from Swiss banks and increasing the allure of hoarding Picas- sos inside humidity-controlled vaults. Bouvier announced plans to build the largest, most technologically sophisticated free port ever, in Singapore, where the art protection laws were even more relaxed than Switzerland's. Not long afterward he announced the construction of another warehouse, in Luxembourg.

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.
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.

In the interviews, Simpson is cagey about some of his business practices, and professes ignorance about the sources used by Christopher Steele, the former British intelligence officer who assembled the reports in the dossier. (Since lying to the committee would be a crime, it’s reasonable to assume his testimony is not deliberately false.) What’s most interesting is all the threads Simpsons mentions about possible Trump connections he’d reviewed with various Russians, with mobsters, and with others. For the most part, they’re just allegations: If Simpson has proof, it’s not disclosed in the transcripts. More often, they seem like tantalizing possibilities worth exploring more, but which Simpson was unable to nail down.


Consistent with general AML principles, the AML Standards stress that beneficial ownership may be obscured behind multiple layers of intermediaries, such as shell companies or offshore companies involving trusts. The AML Standards further provide a list of possible red flags for identifying increased risks of money laundering presented by a client that:
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