"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.
Regardless of whether this provision ultimately is enacted, the underlying issue will persist.  This post discusses some of the general concerns that the art and antiquities world can be misused as a conduit for dirty money.  We then discuss the AML Standards for Art Market Operators proposed by the Basel Institute on Governance, and similar standards set forth by the Responsible Art Market, both of which attempt to set forth a framework for those in the business of trading art to mitigate their money laundering risks.…
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Of course that’s why money laundering exists. One of the simplest ways to do it is to create a web of offshore companies strategically located in countries that don’t ask a lot of questions about where the money came from, but are just happy to take their cut. Many are the usual suspects in the Caribbean, but other favorites include the Seychelles, Cook Islands — which are now being called the Crook Islands by the natives thanks to their sudden surge in popularity as an offshore destination — and of course, Cyprus, which is heavily favored by Russians.
The Italian and other governments are becoming far more aggressive in seeking the repatriation of looted antiquities. Italy in particular waged a long legal battle against Getty curator of antiquities, Marion True, for acquiring illicitly exported pieces, although the case finally exhausted the statute of limitations. And in recent years numerous American museums – including the Metropolitan Museum of Art in New York, Boston’s Museum of Fine Art and the Getty in Los Angeles – have been forced to return looted antiquities to their host countries. These include the famed Etruscan Euphronios krater (wine bowl) dating from 515 BC and which was bought by the Met in 1972 for $1.2m. It turned out that this had also been handled by Medici, and the museum gave it back to Italy in 2006. Just this month, the Getty said it was returning a 12th-century Byzantine illuminated New Testament to the Greek Dionysiou monastery – from which it had disappeared more than 50 years ago.
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.
Open a foreign bank account in a tax haven like Switzerland or the Cayman Islands. Banks in these countries are not required by law to hand over information about your account to anyone without your consent. If you open what's called a “numbered account” in a private Swiss bank like Union Bank of Switzerland or Credit Suisse Group, a number or code name will be associated with the account, rather than your name. To open a numbered account, you will most likely need to travel to Switzerland to do it, though if this is impossible, there are firms that help people set up off-shore bank accounts that can help you. You will most likely need to make an initial deposit of at least $100,000 to open the account, which will cost roughly $300 a year to maintain.
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.
3. Ferromagnetic detectors are becoming a favorite in the contraband smuggling and detection field. The cell phone does not need to be turned on for the detection to happen. The detector picks up the electromagnetic field generated by any mobile phone – even OFF and with the battery removed. The downside is the range is short and sometimes less than a foot.

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.

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.
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 wealthy figured this out in a big way back in the 1980s, giving rise to ‘art stars’ valued in the millions. And with the increasing popularity and geographical scope of biennials and art fairs in the 1990s, rich people all over the world now have access to seas of multi-million dollar investments that can be rolled up and stored just about anywhere.
The potential role of high-end art and antiquities in money laundering schemes has attracted increasing attention over the last several years, particularly as the prices for such objects steadily rise and a tightening global enforcement and regulatory net has rendered other possible avenues for money laundering increasingly less attractive. The effort to subject U.S. dealers in art and antiquities to Anti-Money-Laundering (“AML”) obligations recently has gained new life.  As we blogged, the House Financial Services Committee just released three proposed bills to codify many of the reform ideas that have been swirling around the Bank Secretary Act (“BSA”) and AML and Combating the Financing of Terrorism (“CFT”) laws.  One of the bills — entitled as the “To make reforms to the Federal Bank Secrecy Act and anti-money laundering laws, and for other purposes” —  catalogues various detailed provisions seeking to reform the BSA and AML laws.  Nestled admist all of the other, generally higher-profile proposals (such as the creation of a BSA whistleblower program), one short section of this bill simply expands the list of defined “financial institutions” covered by the BSA to include “dealers in art or antiquities,” and then states that the Secretary of the Treasury shall issue implementing regulations within 180 days of the bill’s enactment.
Recently, some countries in Europe, including Luxembourg and Switzerland, have passed laws to clamp down on money laundering in the art market. Starting in 2016, Switzerland will cap cash transactions at 100,000 Swiss francs ($135,000). Payments above that cash limit will have to be made by credit card, creating a paper trail, or the seller will have to carry out due diligence to ensure the legal origins of the funds.
In regards to the critical issue of the source of the funds, the AML Guidelines “encourage” art businesses “to decline payments from a third party who is not their client and buyer of record. If there are legitimate reasons why it is justified for the Art Business to accept payment from a third party, before doing so the Art Business should conduct enhanced due diligence on both their buyer of record and the third party payer[.]”  The AML Guidelines also articulate a “preference” for art businesses only “to accept payments from reputable banks in jurisdictions subject to AML regulation and supervision.  Such reputable banks and financial institutions are generally subject to a high degree of AML regulation. That said[,] Art Businesses should remain vigilent and not rely entirely on the fact that banks and financial institutions will have carried out the necessary checks and verification to be satisfied that the source of funds is clean.”
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