He told Swiss publication Le Temps that Rybolovlev owes his company “tens of millions of euros,” while claiming that the oligarch set him up after failing to cough up the cash for Rothko’s No. 6 – Violet, Green, and Red. “[Rybolovlev] couldn’t pay the balance of the last painting he bought from my company, the most beautiful Rothko in the world.” Invited by the buyer to chat, Bouvier “fell into an ambush” as he was detained and handcuffed by eight police officers.
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.…
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.
He told Swiss publication Le Temps that Rybolovlev owes his company “tens of millions of euros,” while claiming that the oligarch set him up after failing to cough up the cash for Rothko’s No. 6 – Violet, Green, and Red. “[Rybolovlev] couldn’t pay the balance of the last painting he bought from my company, the most beautiful Rothko in the world.” Invited by the buyer to chat, Bouvier “fell into an ambush” as he was detained and handcuffed by eight police officers.

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.

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If you think that it would be a major oversight to allow people to create plausible deniability just by setting up enough legal entities with limited liability between themselves and their partners, you would be correct. It’s actually illegal under the FCPA, or the Foreign Corrupt Practices Act, which requires basic due diligence prior to making any deals with foreign citizens or in other nations. Domestically, RICO (Racketeer Influenced and Corrupt Organizations Act) goes after opaque arrangements that hide crimes like tax evasion and money laundering to create plausible deniability.
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.
For the collector who sees his 1961 Petrus not as something to drink but as an asset to hoard and potentially sell, Bouvier offered an invaluable service. Items could not only be stored behind the free port's seven-ton doors, surrounded by laser trip wires and vibration detectors, they could be shown to other collectors there and traded or sold without moving an inch—and taxed only if they left the free port. Perhaps the most attractive aspect of all is that such transactions could take place beyond the prying eyes of a district attorney or a private investigator tracking down assets in a divorce battle. (As a result, many in the art world worry about a tendency for free ports to become "art cemeteries." The world's largest free port, at Geneva Airport, is said to hold as much art as the Louvre.)
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We empirically analyze the illicit trade in cultural property and antiques, taking advantage of different reporting incentives between source and destination countries. We generate a measure of illicit trafficking in these goods by comparing imports recorded in United States' customs data and the (purportedly identical) trade recorded by customs authorities in exporting countries. This reporting gap is highly correlated with corruption levels of exporting countries. This correlation is stronger for artifact-rich countries. As a placebo test, we do not observe any such pattern for US imports of toys. We report similar results for four other Western country markets. (JEL F14, K42, Z11, Z13)
This would all just be face-palm silliness on the Times’s part, a reflection of its editorial disconnect between the culture pages and the business staff, if the story didn’t also glide over the real point of what is going on here. The best protected transactions in the art market are those that pass through the auction houses because those firms do the KYC due diligence that squelch money laundering. Auction houses have compliance staff and are easily monitored by the law enforcement which doesn’t crack down on large private transactions that take place through lawyers or dealers.  The Times admits this when they point out that Jho Low passed KYC diligence before it was revealed that he was involved in the 1MDB transactions. After it was revealed, he is no longer able to access art markets through the auction houses.
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.
These funds, as they’re called in Russia, are operated by LLCs that transfer assets, take out loans, and can make a single large organization doing all sorts of questionable deals and making eyebrow-raising purchases when viewed as a single entity, into a web of seemingly unrelated organizations with very different agendas. With enough records to have to sift through, they can hide their affiliations for years, often in plain sight, just because the web is too tangled to really unravel without a very good reason to spend months parsing paperwork.
Around the same time, a lawsuit against Sater and Bayrock is gaining steam, accusing the two key Trump partners in evading taxes on $250 million through various real estate projects the trio would work on. Officially, Sater is no longer an advisor to Trump and says the two just sporadically kept in touch, although in 2016 he would max out contributions to Trump’s presidential campaign and praise him in American and Russian media.
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The King free ports, as the Swiss media have dubbed him, Bouvier was embroiled in a similar legal scandal in 2008, when he was connected to a group that tricked an aging collector into selling a piece by Russian-born French artist Chaim Soutine that was then flipped to the National Gallery of Art in Washington, DC. A suite filed by the heirs of Canadian Lorette Jolles Shefner claims she was misled into selling Piece of Beef for $1 million in the Spring of 2004 by two art experts who, a few months later, sold it to the National Gallery for nearly twice the price. Bouvier was "acting in concert [with the experts] to disguise the true ownership" of works of art as part of the fraudulent scheme, court documents revealed.
In March 2014, Bonhams withdrew a 2,000-year old Assyrian stele estimated at £600,000-£800,000  ($1m-$1.3m) and which was slated for auction on 3 April. The broken stone slab depicting a praying king – and containing a curse in cuneiform which would fall on anyone removing it from its site – was suspected of being looted from eastern Syria at an unknown date. The top half of the slab has been in the British Museum since the late 19th Century. Bonhams says that its piece was withdrawn for “further study”.
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.
Morland was heir to a Quaker dynasty that made a fortune turning sheepskins into coats, and lived a gilded youth: his father was a renowned physician and his mother was a key figure in the modern art world, friend of George Orwell and Henry Moore. At 6ft 3in tall, good looking and well connected, Morland skied for England, had a beautiful wife and children, a des-res in south-west London, a farmhouse in Malta and the world at his feet.
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Though there are no hard statistics on the amount of laundered money invested in art, law enforcements officials and scholars agree they are seeing more of it. The Basel Institute on Governance, a nonprofit research organization in Switzerland — the site of the world’s premier contemporary and Modern art show — warned last year of the high volume of illegal and suspicious transactions involving art. But regulation has been scattershot and difficult to coordinate internationally.
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.
We empirically analyze the illicit trade in cultural property and antiques, taking advantage of different reporting incentives between source and destination countries. We generate a measure of illicit trafficking in these goods by comparing imports recorded in United States' customs data and the (purportedly identical) trade recorded by customs authorities in exporting countries. This reporting gap is highly correlated with corruption levels of exporting countries. This correlation is stronger for artifact-rich countries. As a placebo test, we do not observe any such pattern for US imports of toys. We report similar results for four other Western country markets. (JEL F14, K42, Z11, Z13)
Morland came out to find most of his profits had been lost. His old friends shunned him and the family firm went bust. So for the next thirty years he became a professional yachtsman-smuggler, plying his trade across the Mediterranean, shifting tons of hash, mixing with everyone from Berber tribesmen to gangland heavies, and alternating between periods of sudden wealth and bleak incarceration. In 1980, 1990 and again in 2000, he was caught and jailed for long terms. Now in his early eighties, he lives in “pretty good poverty” and teaches pottery. This is his amazing story.
But the partisan tensions bubbled over again Friday, with a skirmish over a report apparently produced by a splinter faction of Republican members of the House Intelligence Committee led by Nunes. The GOP majority voted Thursday night to share the report with colleagues, but not to release it to the general public. By Friday morning, however, Republican members of Congress were demanding the memo be made public—with their calls being amplified by Russian-linked Twitter accounts.
Borisovich says London’s Russian oligarchs should not be mistaken for conventional, self-made businessmen. “Their riches come from transactions with the Russian government. They either sold something for a fortune to the state of Russia or they bought something for pennies in some sort of privatisation from the state of Russia. Some of them managed to do both, to buy for pennies and sell for fortunes. Some of them never did any of that and they just worked all their life as government officials and somehow in the process became immensely rich,” he says.
The 2,200 photographs by masters like Alfred Stieglitz, Edward Weston and Edward Steichen — more than could fit into an 18-wheeler — were paid for, court papers say, with some of the $78 million that the authorities say Mr. Rivkin got from defrauding oil companies like Shell, Exxon, and Mobil. Mr. Rivkin, who has not been charged with any crimes, was last thought to be in Spain and had arranged to have the photos shipped there.
Though relations between the Republican and Democratic members of the intelligence committee remain contentious, they seem to have improved since Chairman Devin Nunes stepped aside from the investigation amidst a bizarre escapade, in which the White House appeared to be feeding Nunes claims of ethical lapses by the Obama administration in handling intelligence information.
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Of course, beyond AML-related process concerns, any art dealer — just like any business person — always must remember that just about any financial transaction that involves proceeds known to have originated from illegal activity represents a criminal money laundering offense.  Stated otherwise, even if the BSA is not expanded to include dealers in art and antiquities, those in the U.S. art industry still need to bear in mind, in extreme examples, the omnipresent federal criminal code.  Sometimes, the provenance of the funds can be more critical than the provenance of the art.
These funds, as they’re called in Russia, are operated by LLCs that transfer assets, take out loans, and can make a single large organization doing all sorts of questionable deals and making eyebrow-raising purchases when viewed as a single entity, into a web of seemingly unrelated organizations with very different agendas. With enough records to have to sift through, they can hide their affiliations for years, often in plain sight, just because the web is too tangled to really unravel without a very good reason to spend months parsing paperwork.
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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.
The Responsible Art Market, or RAM, is an industry-supported not-for-profit organization which describes itself as ‘”[r]aising awareness of risks faced by the art industry and providing practical guidance on establishing and implementing responsible practices to address those risks.”  On its website, RAM provides both an Art Transaction Due Diligence Toolkit, as well as Guidelines on Combatting Money Laundering and Terrorist Financing (“AML Guidelines”).  The AML Guidelines are similar to the protocols set forth by the Basel Institute, but provide slightly more concrete detail.  They set forth eight basic principles:
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