Well, they are. In 2014, Texas business man Phillip Rivkin was charged with 68 counts of fraud after using millions of dollars worth of photographs to launder money. He had made over $78 million through fraudulent schemes involving his biodiesel production companies—which didn’t actually produce any biodiesel. Rivkin spent roughly $16 million dollars on 2,200 fine art photographs by artists like Edward Steichen, Alfred Stieglitz, and Edward Weston. Works included Edward Weston’s Dunes, Oceano, a gelatin silver print that Rivkin purchased from Sotheby’s for $134,500 and another vintage gelatin silver contact print by Alfred Stieglitz, From the Shelton, West. Rivkin wired Camera Lucida, the seller of the photograph, $150,000 to purchase it.
Bonhams and Christie’s say that they had done research on their pieces, but were hampered by Italian authorities’ refusal to make the photographic database available to auction houses: “While we have a careful due diligence process in all other respects we have no way, without the co-operation of the Carabinieri, of checking this particular database. This case illustrates why that co-operation would be helpful,” said a spokesperson for Christie’s. As for the Roman statue, it was put on display in a New York art fair last year – but failed to sell. The US authorities are hoping to return it to Italy.
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.
Scott has lectured and presented extensively regarding cybersecurity and corporate espionage at numerous conferences around the globe. He has recently overseen the development of several cell phone detection tools used to enforce a “no cell phone policy” in correctional, law enforcement, and secured government facilities. He is regularly interviewed for leading national publications, and major network television stations including Fox, Bloomberg, Good Morning America, CNN, CCTV, CNBC, & MSNBC. He is the author of "Hacked Again" and writes, "In a modern digital world no one is safe from being hacked, not even a renown cybersecurity expert."
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.

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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.

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.

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