Perhaps the most interesting thread is Simpson’s suggestion that the Trump Organization could have been used by Russians to launder money—an arrangement that would have both allowed Kremlin-linked figures to scrub cash and would have created possible blackmail material over the now-president, since the Russian government would be aware that a crime had been committed.
It is hard to imagine a business more custom-made for money laundering, with million-dollar sales conducted in secrecy and with virtually no oversight. What this means in practical terms is that “you can have a transaction where the seller is listed as ‘private collection’ and the buyer is listed as ‘private collection,’ ” said Sharon Cohen Levin, chief of the asset forfeiture unit of the United States attorney’s office in Manhattan. “In any other business, no one would be able to get away with this.”
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.
It is a very pretentious title, but yeah I was a big-time smuggler. I was very ambitious. It all started to get serious when I went to Russia after Beirut. In Russia the art smugglers all worked together so that they could have their claws in many different countries overseas. So if you were "in the game" and a promising prospect like I probably was and had contacts with one clan, you could have contacts with all the clans. I was involved in a big way because I knew all the people and could reach out to them. I could get to the countries behind the iron curtain. I was also dealing with VIPs. Don't think this was some kind of scumbag organization-we were dealing with people who were very high up on the political ladder. All you had to do was make sure everybody had his cut.

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At the restaurant Rappo, who speaks eloquent English as well as French, Russian, and her native Bulgarian, chain-smokes throughout the evening, and although she orders champagne, she scarcely touches it, preferring to talk, talk, and talk. Both her husband, a handsome, quiet man, and her lawyer, "Maître Michel," occasionally interrupt, telling her, "Tania, no, don't say that," but clearly Rappo is not a woman who is told what to do.


He hasn't given many interviews over the past six years, but I managed to track him down for a chat. After learning I did a bit of unlicensed boxing before becoming a journalist, Michel took a liking to me, as he is a fighter himself. He once had so many contracts on his head that Scotland Yard detectives allegedly placed bets on how long he had left to live before he was murdered by a hitman.
He soon joined Ekaterina and Elena in Geneva. However, in their new home, despite their vast wealth, the Rybolovlevs were isolated. Although Elena eventually learned to speak fluent French, her husband "was always distracted by business. I couldn't clear my mind," he says. One of the first friends they made was Tania Rappo, the wife of their dentist, who happened to mention that his wife spoke Russian. (Rappo comes from Bulgaria, where the language is spoken by about a third of the population.)
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.
The problem isn’t their argument that seller’s should reveal themselves. It’s the slapdash evidence and flawed logic they use. The story’s biggest problem begins with the lede where it is argued that real estate sellers are transparent. Several graphs deeper in the story it is revealed that real estate transactions that are on a par with major art transactions are, in fact, not transparent. How do we know that? Because the Times tells us about a pilot program that requires transparency. Here’s the opening graph:
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.
What happened afterward is important, because whatever their disagreements, Rybolovlev and Bouvier agree that the nature of their relationship—whether Bouvier was an agent working for Rybolovlev on a commission basis or an independent art dealer who bought and sold works for himself, freeing him to charge any markup he liked—was never codified on paper. Rappo says that shortly after their encounter at the Geneva free port, Bouvier called her to ask her to arrange a follow-up meeting.
"Mr. R would like to meet you in his office," Bersheda says. "It's cozier." We walk down the hall and confront a wooden door without handles. I pause. It slides apart as if we're in a James Bond movie, and behind it stands Rybolovlev with an unexpectedly warm smile. He's slim and dressed in a crisp blue-and-white-striped shirt, charcoal pants, and black velvet slippers—a signature Russian touch. "Thank you for coming," he says. He looks younger than in photographs, and softer, perhaps because he's not wearing his usual rectangular metal-rimmed spectacles.
Of course, certain countries already impose AML regulations on the art world. The European Union Commission issued its 5th Anti-Money Laundering Directive in June 2018, which must be implemented by Member States by January 2020, and which in part expands its coverage of “obliged entities” to persons trading in art, acting as intermediaries in the trade of art, or storing art in freeports, if the value of the transaction or a group of linked transactions equals €10,000 or more. In the United States, although the BSA already applies to dealers in precious metals, stones and jewels, and thereby requires them to file Suspicious Activity Reports and comply with other AML obligations, no such rules currently apply to U.S. dealers in art.
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