Rybolovlev says he heard through the grapevine that Rappo had gotten richer, acquiring apartments in Paris, London, and Monaco during the years he had known her. Her explanation, he says, was that she had come into a windfall thanks to her family's sale of real estate in Bulgaria. Rybolovlev also said she had given money to Bouvier to invest in the Singapore free port (which Rappo denies), and Bouvier had made her a fortune.
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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.
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Bouvier is accused of fraud and complicity with money laundering along with an accomplice, Tania Rappo, and a third person who hasn’t been immediately identified according to Monaco General Prosecutor Jean-Pierre Dreno, who didn’t respond to Forbes’ requests for comment. The embattled Swiss is out on bail, set at €10 million and to be paid in three installments, and is ready for war.
Over the last decade, economic forces on a global scale have overrun the art world—visibly to all, in the case of the gargantuan bids casually tossed out at the evening sales, but all but imperceptibly (except to a tiny and in-the-know elite) in other areas—and no one has been more at the center of it, or better epitomized its drive for concealment, than the canny Bouvier. In Switzerland a business owned by Bouvier's family, Natural Le Coultre, is one of the country's oldest transporters of goods, formerly of all kinds but since the 2000s of fine art exclusively. The shift in strategy was not coincidental. As the Economist and others have pointed out, "collectibles [such as art] have outperformed stocks over the past decade," aided in part by the world's string of financial crises. In fact, for some ultra-wealthy individuals art has become the asset of choice, for not only does a Modigliani nude hold or increase its value, it is an easy asset to move or hide.
"Mr. R would like to meet you in his office," Bersheda says. "It's cozier." We walk down the hall and confront a wooden door without handles. I pause. It slides apart as if we're in a James Bond movie, and behind it stands Rybolovlev with an unexpectedly warm smile. He's slim and dressed in a crisp blue-and-white-striped shirt, charcoal pants, and black velvet slippers—a signature Russian touch. "Thank you for coming," he says. He looks younger than in photographs, and softer, perhaps because he's not wearing his usual rectangular metal-rimmed spectacles.
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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Borisovich says London’s Russian oligarchs should not be mistaken for conventional, self-made businessmen. “Their riches come from transactions with the Russian government. They either sold something for a fortune to the state of Russia or they bought something for pennies in some sort of privatisation from the state of Russia. Some of them managed to do both, to buy for pennies and sell for fortunes. Some of them never did any of that and they just worked all their life as government officials and somehow in the process became immensely rich,” he says.
Rybolovlev has turned up the legal pressure on Bouvier. Beyond getting him arrested in Monaco, the oligarch’s legal team, headed by Tetiana Bersheda, got Singapore’s High Court to impose a $500 million freeze on Bouvier's assets, his MEI Invest Limited, and supposed accomplice Tania Rappo. In Geneva, public prosecutor Jean-Bernanrd Schmid conducted a search in Natural Le Coultre’s headquarters and a gallery looking for documents related to the Modigliani and Da Vinci transactions. Rybolovlev is operating through the two holding companies that own the art collection, Accent Delight International and Xitrans Finance.
The Responsible Art Market, or RAM, is an industry-supported not-for-profit organization which describes itself as ‘”[r]aising awareness of risks faced by the art industry and providing practical guidance on establishing and implementing responsible practices to address those risks.”  On its website, RAM provides both an Art Transaction Due Diligence Toolkit, as well as Guidelines on Combatting Money Laundering and Terrorist Financing (“AML Guidelines”).  The AML Guidelines are similar to the protocols set forth by the Basel Institute, but provide slightly more concrete detail.  They set forth eight basic principles:
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.”
On April 2nd, the New Directions in Anti-Kleptocracy Forum, organized by the Harriman Institute at Columbia University, will identify emerging issue areas relating to kleptocracy. I am excited to be serving as a co-panelist on the forum’s Art Market as a Node of Kleptocracy panel, which will discuss beneficial ownership and the luxury art market. Money Laundering Watch recently addressed the relationship between art and money laundering, a topic of growing interest.

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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