Of course, certain countries already impose AML regulations on the art world. The European Union Commission issued its 5th Anti-Money Laundering Directive in June 2018, which must be implemented by Member States by January 2020, and which in part expands its coverage of “obliged entities” to persons trading in art, acting as intermediaries in the trade of art, or storing art in freeports, if the value of the transaction or a group of linked transactions equals €10,000 or more. In the United States, although the BSA already applies to dealers in precious metals, stones and jewels, and thereby requires them to file Suspicious Activity Reports and comply with other AML obligations, no such rules currently apply to U.S. dealers in art.


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.
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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.

And then Rybolovlev found out about a New York Times article he had missed from months earlier reporting that the Leonardo he had purchased for $127.5 million had been sold not long before for only $75 million to $80 million. The piece also stated that many experts thought the work had been done by an assistant in Leonardo's studio, not the artist himself.
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).
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