A major player in the art world, Bouvier is well-known for operating free ports in Geneva, Luxembourg, and Singapore. Through his Natural Le Coultre, they are the largest art operator in Geneva with a 22,000 square meter state-of-the-art facility that offers art storage, transport, and favorable tax conditions, and sometimes no taxes at all. At Geneva, reports indicate warehouses hold $100 billion worth of art essentially beyond the taxman's eyes. Bouvier was also behind €150 million arts-park named R4 in Paris, and was also courting the Chinese government to set up a freeport in Beijing.

So the first thing that I would do would be to subpoena the brokers and the people, the other people that were involved in the transactions, and the title  companies and the other intermediaries that would have that kind of information. Then I would go to the banks next. But I actually think some of the intermediary entities in a lot of these transactions are going to be where a lot of the information is….
DMITRY RYBOLOVLEV SELDOM gives interviews. The 49-year-old Russian—one of the richest people in the world, with a net worth estimated at $8.8 billion—is notoriously private, and also notoriously security-conscious, perhaps because back in the 1990s, while building up Uralkali, one of the world's largest fertilizer companies, he survived a year in a Russian prison and several murder attempts.

If the BSA is extended to apply to dealers in art and antinquities, FinCEN can expect a robust notice and comment period for the implementing regulations.  Further, when proposing such regulations, FinCEN might draw upon some existing AML guidelines for the art trade, including those from two not-for-profit groups — one independent, the other supported by industry.  We explore those guidelines in the rest of this post.
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.
Law enforcement officials in the United States and abroad say “Hannibal” is just one of thousands of valuable artworks being used by criminals to hide illicit profits and illegally transfer assets around the globe. As other traditional money-laundering techniques have come under closer scrutiny, smugglers, drug traffickers, arms dealers and the like have increasingly turned to the famously opaque art market, officials say.
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."
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.
If the BSA is extended to apply to dealers in art and antinquities, FinCEN can expect a robust notice and comment period for the implementing regulations.  Further, when proposing such regulations, FinCEN might draw upon some existing AML guidelines for the art trade, including those from two not-for-profit groups — one independent, the other supported by industry.  We explore those guidelines in the rest of this post.
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