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.

He hasn't given many interviews over the past six years, but I managed to track him down for a chat. After learning I did a bit of unlicensed boxing before becoming a journalist, Michel took a liking to me, as he is a fighter himself. He once had so many contracts on his head that Scotland Yard detectives allegedly placed bets on how long he had left to live before he was murdered by a hitman.


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.
Speaking on the sidelines of the Art Business Conference, Pierre Valentin, head of the art law practice at London law firm Constantine Cannon, said laundering illicit funds through the art market was seductive because purchases at auctions "can be anonymous and it's a moveable asset. You can put the art on a private plane and take it anywhere. Plus there is no registration system for art."

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There is no comparable entity in the art market. But were the same type of program instituted in the art market, it would only require that the auction house, dealer or lawyer know the beneficial owner and be able to reveal that information to federal authorities. It would not require the other side of the transaction to learn the seller (or buyer’s) identity.
So, with the help of a girlfriend who speaks better English, the potentate asked Heller, "What price did you sell it for?" The answer: $93 million, $25 million less than Rybolovlev's trusts had paid for it. Chuckling, Rybolovlev tells me his fellow diners at the Eden Rock "thought I was having a stroke." Less cheerfully he says it was the worst New Year's Eve of his life. Within minutes he was on the phone to Bersheda. For years, according to Rybolovlev, he believed he had been paying the middleman who had sold him the Modigliani (above)—as well as 37 other museum-worthy paintings—a commission of 2 percent (in other words, about $2 million for the Modigliani, not $25 million). He was now realizing every collector's worst fear: He had been fleeced, and the question was, for how long and how much?

Bonhams and Christie’s were also forced to pull smaller objects from their March sales this year, after they were alleged to have passed through the hands of two notorious antiquities smugglers, Giacomo Medici and Gianfranco Becchina. Both had been convicted of trafficking in looted objects, for which Medici was sentenced to 10 years in prison and paid a 10m euro fine – the largest ever imposed for such a crime by Italian prosecutors. Polaroid photos of an immense cache of objects in his Swiss warehouse apparently identified a second or first century BC jug offered for £4,000-£6,000 ($6,700-$10,000) at Christie’s, and a third century pottery pyxis (cosmetic pot) offered for £3,000-£5,000 ($5,000-$8,400) at Bonhams. Earlier this year, the US government seized a $4m (£2.4m) ancient Roman statue in a New York warehouse – it too had passed through Becchina’s hands.
Both Bouvier and Rappo would deny the charges, hire lawyers, and spend the following months telling their stories to the media. Bouvier's defense was simple: Yes, he had charged astronomical markups to his client, but, as he told Vanity Fair, "I did not act as intermediary but as the owner [of the art]. I had a right to a profit; it's the law of busi- ness." (Bouvier refused to answer questions for this article.)
In the United States federal money laundering statutes apply to nearly every major transaction through which illegal profits are disguised to look legal. Typically, dirty money is laundered through the purchase of, say, a penthouse apartment, or mixed in with the earnings of a legitimate business like a restaurant. When gambling winnings or drug proceeds come out the other end, they appear as a real estate asset or business profit. They look clean.
“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.”
Edward Winkleman tells us that “transfer of title for digital art happens with an invoice. The collector generally receives a certificate of authenticity, which is required if they ever want to resell or donate the work to a museum. The artwork could indeed be delivered digitally, and payment could indeed be received digitally, but the bank records will show the transaction.”
Pieces started filtering onto the London art market in the 1980s and a British aristocrat, the Marquess of Northampton, formed a consortium to buy 14 of them, along with the late Peter Wilson, at the time chairman of Sotheby’s. Forged documents from Lebanon were produced to give a provenance to the treasure, and it was put up for sale in New York in 1990 at a price of $50m. However immediately three countries – Hungary, Croatia and Lebanon – claimed the cache as being from their territories. The works were hurriedly withdrawn from sale.
Two of the transactions specifically singled out in the complaint are the Modigliani and Leonardo Da Vinci’s Salvator Mundi painted around 1500. While Bouvier is accused of illegally pocketing nearly $25 million on Steve Cohen’s Modigliani, with the Da Vinci—which he’s accused of buying for $75 to $80 million before flipping it to Rybolovlev for $127.5 million including fees—he’s said to have personally received as much as $52.5 million. “I’ve never been a broker,” Bouvier defended himself, “my company was the seller […] and the alleged commissions are not commissions but administrative costs,” he says, adding that in ten years, he’d only spoken to Rybolovlev “five times directly […] he was never a friend.”

"We had a sincere friendship," Rybolovlev says. The two families vacationed together, with the Rybolovlevs often treating the Rappos to trips on private airplanes and their yacht. When Elena gave birth to a second daughter, Tania was asked to be godmother. Meanwhile the Rappos escorted the Rybolovlevs as they began making the rounds, helping them get into an exclusive golf club and chaperoning them to society events. As the Rybolovlevs expanded their real estate empire internationally, Tania Rappo also introduced Rybolovlev to real estate brokers abroad (at his request, she says).

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,
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3G antenna placement Apple cell phone detection cell phone deterrent cell phones cellular signal cellular site cellular test contraband correctional facility court orders court rooms data collection dead zone distracted driving drive test drive testing Drones encryption FBI IoT M2M Machine to machine NSA prison prison contraband prisons privacy radio frequency detector Railway operator distraction receiver RF RF measurements Rikers Island smartphone detection smartphones smuggle topography transmitter UAV WallHound wireless wireless carrier wireless carriers
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.
And in response to Beijing’s strict capital controls which make it illegal for an individual move more than $50,000 out of China per year, wealthy folks from China are turning increasingly to smuggling art out of the country instead. "Items can be bought and sold relatively anonymously, and even when a transaction occurs, complex ownership schemes -- many with a degree of secrecy attached -- are widespread," Paul Tehan of TrackArt, a Hong Kong-based art risk consultancy, told CNN. According to Tehan, senior managers of an art shipping company based in China were arrested for allegedly forging the value of imported art in order to help buyers avoid paying millions in duties.
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.
3G antenna placement Apple cell phone detection cell phone deterrent cell phones cellular signal cellular site cellular test contraband correctional facility court orders court rooms data collection dead zone distracted driving drive test drive testing Drones encryption FBI IoT M2M Machine to machine NSA prison prison contraband prisons privacy radio frequency detector Railway operator distraction receiver RF RF measurements Rikers Island smartphone detection smartphones smuggle topography transmitter UAV WallHound wireless wireless carrier wireless carriers
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.
It is a very pretentious title, but yeah I was a big-time smuggler. I was very ambitious. It all started to get serious when I went to Russia after Beirut. In Russia the art smugglers all worked together so that they could have their claws in many different countries overseas. So if you were "in the game" and a promising prospect like I probably was and had contacts with one clan, you could have contacts with all the clans. I was involved in a big way because I knew all the people and could reach out to them. I could get to the countries behind the iron curtain. I was also dealing with VIPs. Don't think this was some kind of scumbag organization-we were dealing with people who were very high up on the political ladder. All you had to do was make sure everybody had his cut.

Further, and as noted, other traditional vehicles for laundering money have become less attractive, thereby driving those who need a mechanism to launder large sums into the arms of the art world.  As we repeatedly have blogged, one of the most time-honored and relatively convenient vehicles for laundering — real estate — is under intense scrutiny and now is subject in the U.S. to the Financial Crimes Enforcement Network (“FinCEN”)’s ongoing Geographic Targeting Orders (these require U.S. title insurance companies in many parts of the U.S. to identify the natural persons behind legal entities used in purchases of residential real estate involving $300,000 or more and performed without a bank loan or similar form of external financing).
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.”
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