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,


The Harriman Institute strives to facilitate the effective use of the unique resources it possesses to further the work of the diverse community of scholars in residence, students and the more than 60 faculty members who make up the Harriman Institute faculty. Taken together, the library collections of Columbia and the New York Public Library constitute the single largest concentration of Russian-language materials in the country. Moreover, the numerous resources of New York City—the U.N. missions, the many foundations and societies based in the city, the wealth of museums, special collections and archives, to name just a few—ideally complement those of Columbia University.
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.
Like most laundering cases involving art in the United States, this one was uncovered when the work was illegally transported into the country. In 2004 Mr. Ferreira’s financial empire, built partly on embezzled funds, collapsed, leaving $1 billion in debts. A court in São Paulo sentenced him in 2006 to 21 years in prison for bank fraud, tax evasion and money laundering, a conviction he is appealing. Before his arrest, however, more than $30 million of art owned by Mr. Ferreira and his wife, Márcia, was smuggled out of Brazil, Judge De Sanctis said.

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.
The Art Business should examine the client’s background and purpose behind the contemplated transaction. For example, are the artworks being sold by the client consistent with what is known about the client’s collection? Is the level at which the client is selling or buying consistent with their past transactions and what is known about their professional activities and personal wealth? If not, the Art Business may want to ask the client for further information.
At first Rybolovlev collected slowly, buying a handful of works, including a Monet water lily painting, Gauguin's House of Hymns, three Picassos, and three Modiglianis. After 2009, however, the pace quickened. Rybolovlev was no longer interested in decorating his walls with museum pieces, he says, perhaps because the walls themselves were a subject of dispute.

Last year, when she found out Elena had been arrested, she says she got nervous; she calls the event a turning point in her relationship with Dmitry. (If so, Rybolovlev says he didn't notice—Rappo still showed up for events he held.) The arrest had taken place during a visit to Cyprus, where Rybolovlev has considerable financial assets, including at one time a large stake in the country's biggest bank. Rappo says Rybolovlev told her, "There are three places in the world I can do whatever I want. One is Cyprus, one is Skorpios, and the other is Monaco." And she claims he had Elena arrested—even though she spent only a short while in custody—to scare her into dropping her lawsuits (filed in several countries) in pursuit of her ex-husband's money.

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.”


He told Swiss publication Le Temps that Rybolovlev owes his company “tens of millions of euros,” while claiming that the oligarch set him up after failing to cough up the cash for Rothko’s No. 6 – Violet, Green, and Red. “[Rybolovlev] couldn’t pay the balance of the last painting he bought from my company, the most beautiful Rothko in the world.” Invited by the buyer to chat, Bouvier “fell into an ambush” as he was detained and handcuffed by eight police officers.
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.
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