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.”
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.
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.

"There is a saying in French: When you want to get rid of your dog, say it has rabies," Rappo says. "He wanted to discredit Bouvier." And as for his putative vendetta against Rappo? She alleges that Rybolovlev and his lawyers have gone after her and not just Bouvier because they "must find a way to link the case to Monaco. The paintings were not sold here."
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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.”
But his suspicion was not triggered until Bouvier came to Rybolovlev in 2013 and 2014 to shop two paintings, first Salvator Mundi, a recently discovered Leonardo for which he wanted $127 million, and then No. 6 (Violet, Green and Red), a prized Rothko for which he requested $140 million. Rybolovlev told Bouvier that the family trusts would pay for the Rothko only in installments while Bouvier sold other works, including a Modigliani sculpture Rybolovlev had owned since 2012. Bouvier seemed to have trouble finding a buyer for the Modigliani—or "anything!" Rybolovlev says.
According to Bersheda, the criminal complaint she filed last year was against Bouvier only. Rybolovlev was already hurt and angry, but the serious pain came, he says, when he heard that investigators had found commissions from Bouvier in Rappo's bank accounts going back to 2004. Rappo knew Rybolovlev to be reserved and wary, he says. He let his guard down around Bouvier because he trusted her. At that point he began to see Rappo, not Bouvier, at the center of the spider's web. Their falling out has led him to ask what he calls "difficult philosophical questions." Had it not been for the dentist's wife he would never have gotten involved with Bouvier.
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.
The story came to a partial resolution last month, when the Hungarian government announced that it had acquired seven of the 14 pieces from the heirs of Peter Wilson for  €15m (£12.4m). As for the Northampton part of the cache, its fate remains mysterious: Lord Northampton divorced his fifth wife in 2012 with a secret settlement said to be worth £17m: it is not known if she received part of the hoard in the deal.
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.
In the tight-knit world of art dealers and mega-buyers, where insider information is the name of the game, Bouvier's case could be prove to be a game changer, as it potentially pits collectors against brokers, putting inherent conflicts of interest in the spotlight. At the same time, Rybolovlev is playing a high-stakes game, as a sophisticated collector and global businessman of his stature is not one who doesn't understand the risks he's taking. His lawyer claims other "victims" of Mr. Bouvier have already approached them, while the embattled King of the free ports believes he will clear his name in a Monaco court. Whatever happens the impact could be permanent.
Francis Morland was one of Britain’s most talented young artists, a contemporary of David Hockney and Peter Blake and a leading member of the 1960s “New Generation” movement. At the same time he lived an even more remarkable secret life as the biggest drug trafficker in the UK. He stuffed his abstract sculptures full of Lebanese cannabis to ship to the lucrative American market, moved yachtloads of Moroccan hashish to Europe, and years before Howard Marks, became the country’s first recognised drug baron.
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.
He soon joined Ekaterina and Elena in Geneva. However, in their new home, despite their vast wealth, the Rybolovlevs were isolated. Although Elena eventually learned to speak fluent French, her husband "was always distracted by business. I couldn't clear my mind," he says. One of the first friends they made was Tania Rappo, the wife of their dentist, who happened to mention that his wife spoke Russian. (Rappo comes from Bulgaria, where the language is spoken by about a third of the population.)
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.
At our meeting at La Belle Epoque I put it to him: Had he been conned or was he negligent? The answer, he explained, went back to the early 1990s, before he and his family fled Russia. After the fall of communism, Rybolovlev, who originally trained as a cardiologist, switched to finance and became one of the first securities traders in Russia. One of his first moves as a financier was to take a majority stake in Uralkali, the former Soviet fertilizer monopoly, which subsequently increased its productivity five-fold. Boris Yeltsin was president. The economy of Russia was melting down. The rule of law had all but disappeared, and Uralkali's success made Rybolovlev a target. To protect himself from ambushes he sent a fleet of identical cars with identical license plates registered in his name into Moscow; he also moved Ekaterina and his wife Elena to Geneva.

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.
"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.

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.
In the tight-knit world of art dealers and mega-buyers, where insider information is the name of the game, Bouvier's case could be prove to be a game changer, as it potentially pits collectors against brokers, putting inherent conflicts of interest in the spotlight. At the same time, Rybolovlev is playing a high-stakes game, as a sophisticated collector and global businessman of his stature is not one who doesn't understand the risks he's taking. His lawyer claims other "victims" of Mr. Bouvier have already approached them, while the embattled King of the free ports believes he will clear his name in a Monaco court. Whatever happens the impact could be permanent.
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These offshore companies can cross borders, invest and transfer cash between each other, and after creating a frustrating enough web of transfers and exchanges, as many of them as vague and anonymous as possible mid-transit, they can invest in money-making ventures. Over time, they build small empires in their target destinations, which for Russians are often Switzerland and the UK, particularly London. But that’s fairly basic. The real pros are a lot sneakier than that, using charitable organizations and nonprofits as their identity shields.
We went with the police and about 20 Nigerians into the gallery the day before the opening. There were all of these fucking posh people sipping champagne, and in we came to shut it down. You should've seen their fucking jaws! I made a statement: "Don't touch the heritage of these people!" And it's not that I was a white knight-not at all. But I began to come across certain things that I just couldn't step over.
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.
Other valuable customers for the auction houses and dealers were Malaysian businessmen who, beginning in 2013, bought more than $200 million in art, usually operating as the Tanore Finance Corporation, including eight works at Christie’s. The United States government contends in a civil complaint that the art was purchased with money that had been embezzled from Malaysian government accounts and that the ultimate beneficiary was Jho Low, one of the businessmen. Mr. Low, who has denied any wrongdoing, has not been criminally charged.
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He returned in 1996, trying to build yet another hotel in partnership with a tobacco company. That deal also went nowhere, but Trump was able to successfully apply for Trump Russia trademarks. Ultimately, he never built anything there, but by the early 2000s, his units were suddenly a hit with wealthy Russians. His properties in Florida and NYC are especially popular, with Russian real estate agent Ilya Reznik telling the press that Coastal Miami is often pitched as Little Moscow.
Francis Morland was one of Britain’s most talented young artists, a contemporary of David Hockney and Peter Blake and a leading member of the 1960s “New Generation” movement. At the same time he lived an even more remarkable secret life as the biggest drug trafficker in the UK. He stuffed his abstract sculptures full of Lebanese cannabis to ship to the lucrative American market, moved yachtloads of Moroccan hashish to Europe, and years before Howard Marks, became the country’s first recognised drug baron.
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On April 17, 2019, the United States Attorney’s Office for the Southern District of Florida (the “Government”) announced its non-prosecution agreement (available here) entered into with a Miami-based gold refinery, Republic Metals Corp. (“RMC”), related to the refinery’s failure to maintain a robust anti-money laundering (“AML”) program. RMC is the second American refinery whose AML program has been identified as deficient by the Government as part of its ongoing probe into gold imports from South American countries such as Peru, Bolivia, and Ecuador (dubbed “Operation Arch Stanton”). The Government’s decision to decline prosecution against RMC stands in stark contrast to its prosecution last year of another refinery, Texas-based Elemetal LLC (“Elemetal”), arising from the same probe.…
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.
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.

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.
“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.”
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.
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