"I think I can be useful," Rappo says Bouvier told her. Rybolovlev "jumped," she says. "He was really very happy." According to her, the oligarch recognized that Bouvier had some of the best art in the world sitting in his Geneva warehouse. Rybolovlev, for his part, says he scarcely remembers his first meeting with Bouvier, and he took the meeting only because Rappo encouraged him to. He found Bouvier "a regular, likable man," different from the stereotypical smooth-talking art dealer. And because Rappo, whom he trusted "totally," had brought them together, Rybolovlev agreed to work with him for, the oligarch claims, a fee of 2 percent—which Bouvier denies, saying that amount was merely for transport and administrative costs.
When addressing the efforts to establish an artwork’s provenance history and authenticity under Guideline 4, the AML Guidelines provide that “[i]t is important to obtain and publish in any catalogue or sales document as much information as possible about the artwork, including any known provenance,” and to “check major databases of stolen and looted art and obtain any relevant and available legal documents, witness declarations, [and] expert opinions[.]” In addition to a physical examination of the artwork and a technical analysis and dating of the materials used, “[d]ocuments helpful in establishing ownership and provenance include invoices, receipts, dated photographs, insurance records, valuations, official records, exhibition catalogues, invoices for restoration work, diaries, dated newspaper articles, original signed and dated letters.”
In 2008, Elena Rybolovleva, Dmitry's wife of 24 years, whom he met on the first day at medical college back in Russia, filed for divorce, citing adultery on an industrial scale, including parties aboard yachts at which Dmitry shared "young conquests with his friends and other oligarchs." ("He was not a model husband," a spokesman for Dmitry later told the New York Times. "Mr. Rybolovlev never denied the infidelities, but the wife knew about it for many years and passively accepted it.") In the wake of what would become an exceptionally acrimonious divorce battle (which included Elena's being arrested in Cyprus for allegedly stealing a $28 million diamond ring she later proved her ex- husband had given her while they were still married), Dmitry began seeing art as an investment for his daughters' futures, he says. He subsequently started moving the collection into vaults (trophy works by Matisse, Klimt, Rodin, and Magritte by now had joined the stockpile). The art was owned by trusts, which, Elena complained, were designed to thwart her access to the couple's fortune in divorce court. The divorce (which, Dmitry confided exclusively to T&C, was finally settled in October for an undisclosed amount) was at one time famous for being the most expensive in the world, after a Geneva judge awarded Elena half of her ex-husband's fortune, some $4 billion.
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.

Most of these industries have checks. Real estate titles and deeds at least require a name. Mortgage brokers, stockbrokers, casinos, banks and Western Union must report suspicious financial activity to the federal Financial Crimes Enforcement Network. Banks must report all transactions of $10,000 or more. Altogether, the network logs more than 15 million currency transactions each year that can be used to track dirty money, said Steve Hudak, a spokesman for the agency. The art market lacks these safeguards. Roll up a canvas and it is easy to stash or move between countries; prices can be raised or lowered by millions of dollars in a heartbeat; and the names of buyers and sellers tend to be guarded zealously, leaving law enforcement to guess who was involved, where the money came from and whether the price was suspicious.
The Wolf of Wall Street was a hit when it was released in 2013. Moviegoers all over the world loved the story of excessive wealth and greed. But most people didn’t know that the movie was partially funded by a money-laundering scheme involving famous works of art. Malaysian Prime Minister, Najib Razak, had siphoned part of a $1 billion fortune from the Malaysian sovereign wealth fund into American assets, such as real estate and paintings by Basquiat, Rothko, and Van Gogh.
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.
Briefly: On New Year's Eve 2014, Rybolovlev found himself at the Eden Rock St. Bart's eating with Sandy Heller, a New York art consultant who advises many hedge fund managers. Somewhat obliquely Heller said, "It looks like you bought the Modigliani [we sold]." He was referring to Reclining Nude with Blue Cushion, one of the artist's most famous canvases, painted in 1917. The painting had belonged to Steven A. Cohen, the founder of SAC Capital Advisors and also one of the richest men in the world.
In the early 2000s, Brazilian financier Edmar Cid Ferreira had embezzled funds from his business empire — and he needed a way to hide the money. He found it in Hannibal, a painting by American artist Jean-Michel Basquiat. Appraised by the art world at $8 million, Ferreira showed up at New York’s Kennedy Airport in 2007 with the painting and a bill of lading listing the value as $100.
Tucked behind Kensington Palace and protected by armed police at checkpoints on either end is the street known as Billionaire’s Row, the most expensive in London and perhaps the world. A private road owned by the Crown Estates, traffic is light and slow here, and a prohibition on photography is enforced by the private security guards who watch over every other house.
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“Russia had no institutional instruments for regulating this new commercial environment. The courts didn’t function. They didn’t know what dispute resolution in business actually was. And so everyone engaging in the new commerce had to employ their own security force in order to ensure the integrity of their business contracts. These guys were called privatised law enforcement agencies by sociologists but they are quite simply the Mafia,” he says.
When confronted, his company merely says that it’s not involved in any deals beyond licensing a brand name and image. In fact, his blinders about the identity of those backing Trump Towers Baku is a repeat of a 2010 deal in which a state-run Russian bank, which serves as a slush fund for Putin’s projects and is directly overseen by him was indirectly involved in a textbook case of money laundering.
But what we’re seeing is a pattern of Trump in the midst of wealthy foreigners engaged in money laundering schemes that center around real estate, and not bothering to vet any of them before doing business. Furthermore, there’s also the fact that he proudly claims to be the owner of more than 500 companies with very complex finances, which is a massive red flag in this context.
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.
And Sater was far from the only person with shady connections doing business with Trump. In 2008, oligarch and fertilizer magnate Dmitry Rybolovlev bought a Trump property for double what it was worth, which can be a classic money laundering technique meant to bake payments or bribes into what looks like a real estate deal. It seems hard to believe that Rybolovlev would think that a $41 million property more than doubled in value in less than a year.
The following year, in 2013, an even more high-profile laundering case surfaced when a Jean-Michel Basquiat painting worth $8 million was found in a crate at Kennedy Airport on its way from London. The crate went through customs with a valuation of $100, though it contained Basquiat’s 1982 painting Hannibal (commodities valued under $200 aren’t required to be declared at customs.) The painting had been bought and shipped by Brazilian Banker Edemar cid Ferreira in an elaborate scheme to launder over $50 million that was illegally obtained when Ferreira’s bank, Banco Santos, went bankrupt. In 2004, Ferreira went $1 billion in debt after his financial empire, much of which was built on embezzled funds, collapsed. During his reign over Banco Santos, he had bought 12,000 pieces of art. In 2006, Ferreira was sentenced to 21 years in prison for bank fraud, tax evasion, and money laundering. But before his arrest, $30 million of his art collection was smuggled out of Brazil. The scheme was uncovered when Hannibal was found at JFK. According to court papers, the painting was originally bought for $1 million in 2004 by a Panamanian company called Broadening-Info Enterprises, which was later discovered to be owned by Ferreira’s wife, Márcia.
In the end, maybe this guide was never intended for amoral businessmen in the first place (unless we’ve sorely misjudged our readership!) Maybe this it's more useful to the emerging artists who look for validation (read: dollar signs) in a competitive market. Maybe the artist’s secret to success is appealing to the corrupt and becoming an accomplice to white collar crime (but hopefully not). Are economic criminals the driving force of the art economy? Probably not, but what we do know for certain is that art isn’t only valuable as the evidence of creative genius. It is, to many, a vault.
Schiff accused Republicans who have circulated the memo of carrying water for the White House. “It’s a bit of a hodgepodge of false statements and misleading representations,” he said, and argued that the report sought to mislead the public, relying on the expectation that the classified information that underpins and contextualizes it would never be made public.
But what we’re seeing is a pattern of Trump in the midst of wealthy foreigners engaged in money laundering schemes that center around real estate, and not bothering to vet any of them before doing business. Furthermore, there’s also the fact that he proudly claims to be the owner of more than 500 companies with very complex finances, which is a massive red flag in this context.

The debate about anonymity in the art world has intensified over the past year, fed in part by the release of the so-called Panama Papers, which detailed the use of corporate veils to conceal ownership, dodge taxes and enable crime, its authors say. Now various expert groups, like the Basel Institute, are coming forward with ways for dealers and auction houses to curb secrecy and combat money laundering. In a significant change, Christie’s said last week it has strengthened its policy in recent months and now requires agents looking to sell a work through the auction house to tell it the name of the owner they represent.

Rybolovlev now says he didn't want his marriage to end—nor, he felt, did Elena. He believes it could have been saved, but Rappo, whom Elena was close to, "pushed her"—his words—not to reconcile, because, he says, Rappo (and Bouvier, with whom he believes Rappo had formed a secret partnership) wanted "the story of my divorce" to cover what he calls Rappo and Bouvier's unfolding scheme. That alleged plot, which Rappo and Bouvier deny, involved defrauding Rybolovlev—hiding from him the enormous markups on the masterpieces he was acquiring through them—in order to finance an ambitious expansion of Bouvier's free port empire. And Rybolovlev, even if he found out, would have no choice but to go along.
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.
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.
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,
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.
The room is oval and intimate. He sits in an armchair, back to flung-open French doors, the yacht-filled harbor of La Condamine beyond. Curiously, since Rybolovlev is the owner of one of the world's most valuable art collections, not a single work of art is on view. However, books, mainly on business and soccer, line the shelves. When I point out one by Donald Trump, he laughs. "I've never read it," he says. "It was put there by the Candy brothers." I sit on the sofa close to Bersheda, who is going to translate. Rybolovlev's trust in the glamorous, brainy 31-year-old lawyer is obvious. They met six years ago in Geneva, where she worked for a law firm that he had retained. He asked her to work for him and she refused, but subsequently she set up her own firm, of which he is now a major client. She and I met last summer at Art Basel, where she gauged whether he should talk to me.
Keep in mind that Kislyak is the same Russian ambassador who routinely met with numerous members of Trump’s campaign throughout 2016, discussing sanctions, Syria, and Crimea. If Trump really didn’t know what was going on, why is his son-in-law meeting with a bank that has spent years trying to avoid sanctions for laundering money for Putin’s inner circle and controlled by the Russian President himself? If we believe he was that oblivious, Trump’s ignorance of his own business operations would beggar belief.

The Chinese art market, where regulation is lax, is thought to be particularly prone to money laundering. "The [Chinese] art market has become more and more abnormal," Wang Shouzhi, dean of the Cheung Kong School of Art and Design at Shantou University, told the South China Morning Post in April. "It is saturated with business tricks, fake works and fake prices. … It has become a tool for corruption and money laundering."


Their money leaves Russia to be laundered, usually through Cyprus and then on to the British Virgin Islands, where offshore companies are set up, often owned by offshore trusts based in places such as Gibraltar. Thoroughly washed, it arrives in London to be invested in the property market, with Russians often prepared to pay well above the odds for a prestigious property.
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Of course, beyond AML-related process concerns, any art dealer — just like any business person — always must remember that just about any financial transaction that involves proceeds known to have originated from illegal activity represents a criminal money laundering offense.  Stated otherwise, even if the BSA is not expanded to include dealers in art and antiquities, those in the U.S. art industry still need to bear in mind, in extreme examples, the omnipresent federal criminal code.  Sometimes, the provenance of the funds can be more critical than the provenance of the art.
The anecdote about Steve Cohen’s Modigliani comes straight out of the criminal complaint received on January 12, 2015 by Monaco’s Palais de Justice, and was confirmed by source close to the matter. While Bouvier may not be a household name in the U.S., the accusations and ensuing arrest reverberated across the European art market, where Bouvier runs a set of luxury warehouses across Geneva, Luxembourg, and Singapore where the world’s billionaires store their art, along with jewels, fine wines, and other luxury goods legally in tax-free zones.
I always faced my problems. You have to show some balls. Funnily enough, a lot of these hitmen, if they are cut from the right cloth, will come to you with a certain respect if you don't hide. When the Yugoslavian mafia were going to kidnap my father and brother for trying to set a sting operation against them, I had to come back to Amsterdam to face it. I said, "OK, come along. If you're going to kill me, kill me. If you want my money, go fuck yourself." That's the language they speak. I was standing with my bodyguards on the terrace in Amsterdam and this car flew past and they started shooting at me. A bullet went straight through my leg.
In this light Trump’s sprawling empire with deep ties to corrupt Russians looks less like a thriving real estate business, but something a bit more nefarious. Deniability was so built into the way he operated that his lawyers didn’t want him signing his own financial disclosures. The Donald’s Sergeant Schultz cavalier approach to business and political conflicts of interest mirror Russian oligarchs. In 2015, as Trump began to eat up air time on American political talk shows in the same way that a starving man eats his first meal in days, Putin may have sensed an opportunity…
“Before we looked into the allegations that Trump campaign people were surreptitiously meeting with the Russians it was only an allegation, but it proved to be all too true,” Schiff said. “Before we looked into allegations that Mike Flynn was having secret communications with the Russians and that the Trump transition might be seeking to undermine the sanctions imposed on Russia over its interference to help the Trump campaign, that was only an allegation, but that proved to be true. There's simply no way to either verify or be able to dismiss these serious allegations without looking into them.”
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.
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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.
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.
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— The United Nations Office on Drugs and Crime estimates the amount of illicit money that is laundered each year to be between “2 - 5% of global GDP, or $800 billion - $2 trillion in current US dollars.” The difficulty of knowing exact figures accounts for the huge margin within estimates. The UN’s estimates specifically cite “Mega-Byte” as an issue, defining the term as “money in the form of symbols on computer screens the can move anywhere in the world with speed and ease.”
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