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.

You always have to be a step ahead of them. Most of them you could pay off, but some you couldn't. I was cocky. I would show off in their faces sometimes. It was stupidity, but I saw the news of my smuggling in the papers and I liked it, it showed them I could still do it even though they were after me. Also I'd travel on fake passports and change my appearance. Instead of blue eyes I'd change them to brown with contacts, I'd dye my hair blonde... all those corny tricks. At that time they worked.


When addressing the efforts to establish an artwork’s provenance history and authenticity under Guideline 4, the AML Guidelines provide that “[i]t is important to obtain and publish in any catalogue or sales document as much information as possible about the artwork, including any known provenance,” and to “check major databases of stolen and looted art and obtain any relevant and available legal documents, witness declarations, [and] expert opinions[.]” In addition to a physical examination of the artwork and a technical analysis and dating of the materials used, “[d]ocuments helpful in establishing ownership and provenance include invoices, receipts, dated photographs, insurance records, valuations, official records, exhibition catalogues, invoices for restoration work, diaries, dated newspaper articles, original signed and dated letters.”
Schiff accused Republicans who have circulated the memo of carrying water for the White House. “It’s a bit of a hodgepodge of false statements and misleading representations,” he said, and argued that the report sought to mislead the public, relying on the expectation that the classified information that underpins and contextualizes it would never be made public.
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The debate about anonymity in the art world has intensified over the past year, fed in part by the release of the so-called Panama Papers, which detailed the use of corporate veils to conceal ownership, dodge taxes and enable crime, its authors say. Now various expert groups, like the Basel Institute, are coming forward with ways for dealers and auction houses to curb secrecy and combat money laundering. In a significant change, Christie’s said last week it has strengthened its policy in recent months and now requires agents looking to sell a work through the auction house to tell it the name of the owner they represent.
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.

We empirically analyze the illicit trade in cultural property and antiques, taking advantage of different reporting incentives between source and destination countries. We thus generate a measure of illicit trafficking in these goods based on the difference between imports recorded in United States' customs data and the (purportedly identical) trade as recorded by customs authorities in exporting countries. We find that this reporting gap is highly correlated with the corruption level of the exporting country as measured by commonly used survey-based indicies, and that this correlation is stronger for artifact-rich countries. As a placebo test, we do not observe any such pattern for U.S. imports of toys from these same exporters. We report similar results for four other Western country markets. Our analysis provides a useful framework for studying trade in illicit goods. Further, our results provide empirical confirmation that survey-based corruption indicies are informative, as they are correlated with an objective measure of illicit activity.


Once purchased, the art can disappear from view for years, even decades. A lot of the art bought at auctions goes to freeports – ultra-secure warehouses for the collections of millionaires and billionaires, ranging from Picassos and gold to vintage Ferraris and fine wine. The freeports, which exist in Switzerland, Luxembourg and Singapore, offer a variety of tax advantages because the goods stored in them are technically in transit. The Economist magazine reported that the freeport near the Geneva airport alone is thought to hold $100-billion (U.S.) of art.
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When addressing the efforts to establish an artwork’s provenance history and authenticity under Guideline 4, the AML Guidelines provide that “[i]t is important to obtain and publish in any catalogue or sales document as much information as possible about the artwork, including any known provenance,” and to “check major databases of stolen and looted art and obtain any relevant and available legal documents, witness declarations, [and] expert opinions[.]” In addition to a physical examination of the artwork and a technical analysis and dating of the materials used, “[d]ocuments helpful in establishing ownership and provenance include invoices, receipts, dated photographs, insurance records, valuations, official records, exhibition catalogues, invoices for restoration work, diaries, dated newspaper articles, original signed and dated letters.”

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.
Trump’s $125 million asking price for the so-called House of Friendship should’ve scared off any potential buyers, never mind get an offer at $95 million for a house in which the owner would never set foot and tear it down while doing absolutely nothing with it for eight years. Would he not get suspicious about the Russian billionaire wildly overspending on real estate?
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Around 2003 the Rybolovlevs decided to build an art collection—"the best in the world," Dmitry has been quoted as saying. They had recently moved into a house with light fixtures for art displays, and with the help of Rappo they were making inroads among a Western European elite that spent its considerable wealth on art. Rybolovlev soon settled on his first acquisition: Le Grand Cirque, one of Marc Chagall's many beloved circus paintings. (The previous owner of the house, who had left the fixtures, owned a Chagall.) He consulted several dealers, and the best price was $8 million, according to Rappo. However, she came up with a way to eliminate the dealers and buy directly from Le Grand Cirque's owner, lowering the price by more than $2 million—and, pivotally, bringing Rybolovlev into contact with Yves Bouvier.
Rybolovlev ultimately invited me to La Belle Epoque because he has a story to tell, or rather explain. For the last year he has been at the center of the most astonishing scandal in the art world in years, an alleged billion-dollar fraud that has dealers, artists, and collectors sweating. At stake may be not just the money of an angry and very powerful man intent on recouping his losses but the thing the art world values more than anything: the freedom to operate in darkness.
At the same time, Trump partnered with a real estate developer called Bayrock, founded by Soviet-born Tevfik Ariv who set up office in Trump Tower. In 1999, Russian-born former gangster implicated in a Wall Street pump-and-dump scheme and money laundering, Felix Sater, joined Bayrock and would become a top Trump adviser. Sater claimed they would talk often, with him pitching ideas on a regular basis. By 2005, the duo is trying yet again to build a hotel in Moscow to no avail.
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 this light Trump’s sprawling empire with deep ties to corrupt Russians looks less like a thriving real estate business, but something a bit more nefarious. Deniability was so built into the way he operated that his lawyers didn’t want him signing his own financial disclosures. The Donald’s Sergeant Schultz cavalier approach to business and political conflicts of interest mirror Russian oligarchs. In 2015, as Trump began to eat up air time on American political talk shows in the same way that a starving man eats his first meal in days, Putin may have sensed an opportunity…
Rybolovlev says he heard through the grapevine that Rappo had gotten richer, acquiring apartments in Paris, London, and Monaco during the years he had known her. Her explanation, he says, was that she had come into a windfall thanks to her family's sale of real estate in Bulgaria. Rybolovlev also said she had given money to Bouvier to invest in the Singapore free port (which Rappo denies), and Bouvier had made her a fortune.

The AML Standards for Art Market Operators (“AML Standards”) are set forth by the Basel Institute on Governance, an independent not-for-profit organization.  Not surprisingly, the AML Standards adopt a “risk based” approach to establishing measures to mitigate money laundering risks, and further note that “[s]mall businesses may not have the resources to address money-laundering risks in the same way that large auction houses or major dealers and galleries will have, and may have a different risk exposure.”  The AML Standards are intended to apply to everone trading in art objects, and intermediaries between buyers and sellers.  They also suggest that service industries supprting the trade in art objects that are already subject to AML laws, like financial institutions, should identify their clients and customers in the art trade “as higher risk as long as there are no internationally applicable standards.”

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