Let’s get back to the real estate pilot program that lies at the heart of the Times’s confusion. That federal program, which may or may not be continued, relies upon mortgage title insurance companies to report to authorities the ultimate beneficial owner of any vehicle used to buy or sell very valuable real estate. It does not require the seller to reveal the beneficial owner to the buyer or vice versa.
But given his recent history of making splashy but unsupported claims, it’s difficult to grant Nunes the benefit of the doubt. In the spring, he made a series of extremely serious allegations against the Obama administration, including improper surveillance of Trump aides. No proof of those allegations emerged, and the Justice Department has since said there was no surveillance. It soon became clear that Nunes was receiving information from White House staffers (who have since been pushed out of the White House), even as he was overseeing an ostensibly independent investigation into the president.
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The data also shows payments to talent agencies, in London and California. The Laundromat was used to book artists on tours of Russia. They include the Florida rock band the Red Jumpsuit Apparatus and Israeli singer-songwriter Yoav. Both played in Moscow and St Petersburg in the autumn of 2013. There is no suggestion the artists were aware of the scheme.
To sum up, the Times muddles the very different issues of ensuring the integrity of works of art—the authenticity question—which is real and requires an entity that can work with owners who want to maintain their anonymity for legitimate reasons with the issue of beneficial ownership—which is less pressing with art because it is relatively rare and covered by the parallel system of KYC run by the banks the auction houses rely upon to vouch for their clients’ ability to afford the works they want to buy.

It was, but things changed later when I went to the Jos Plateau in Nigeria. I saw these incredible Nok terracotta heads that they bury in the graves for their ancestors. They were potentially million-dollar pieces and I was there to buy them. But then I met the people-the Jos Plateau is very cold at night so we sat around campfires-and they hardly had anything to eat, yet they sit up all night to protect their ancestor's culture from vultures who want to come and dig and steal and kill to get the terracottas. That touches your heart. You can't deal with those things. You don't want to have people dying for art. It was all just a game, but then I was on top of that hill and suddenly confronted with reality. If that doesn't change you, you aren't a human being.
Michel: Well, by the time I was 15 I had been kicked out of seven schools. I must have been ADHD or whatever, because I fucking hated school and was always looking to start something for myself. So I began importing cheap hippie coats from Istanbul. They were basically sheepskins turned inside out with some sleeves on them. I began selling them in this hashish bar in Holland. They sold like fucking hotcakes. So I was going up and down between Istanbul and Holland quite a lot. Business was going well, and I was eventually approached in Istanbul by a man named E.
To sum up, the Times muddles the very different issues of ensuring the integrity of works of art—the authenticity question—which is real and requires an entity that can work with owners who want to maintain their anonymity for legitimate reasons with the issue of beneficial ownership—which is less pressing with art because it is relatively rare and covered by the parallel system of KYC run by the banks the auction houses rely upon to vouch for their clients’ ability to afford the works they want to buy.
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.
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So far, the release of transcripts of Fusion GPS founder Glenn Simpson’s interviews with the House Intelligence and Senate Judiciary committees have provided rich detail to obsessives but few major headlines for the average reader. The interviews give some more clarity on how Fusion came to investigate Donald Trump; who was paying the company; and how it gathered information, but they offer much help in assessing the Trump dossier.

Finally, under Guideline 6, the AML Guidelines provides that art businesses must maintain adequate records of their due diligence efforts. Perhaps stating the obvious, but perhaps also implicitly acknowledging the existence of practices by certain dealers, the AML Guidelines observe that “[a]ll documents issued by an Art Business in connection with a transaction (e.g. valuations, sale and purchase agreements, invoices, shipping documents, import / export declarations etc.) should be true, accurate and contemporaneous and represent the honestly held professional opinions of the Art Business.” Likewise, dealers “should refuse all requests from clients to alter, back date, falsify or otherwise provide incomplete or misleading documentation or information relating to a transaction. If there are legitimate reasons for altering a document (e.g. invoicing error etc.) the circumstances and justification should be fully documented and retained on file for future reference and audit.”
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"There is a saying in French: When you want to get rid of your dog, say it has rabies," Rappo says. "He wanted to discredit Bouvier." And as for his putative vendetta against Rappo? She alleges that Rybolovlev and his lawyers have gone after her and not just Bouvier because they "must find a way to link the case to Monaco. The paintings were not sold here."

In the tight-knit world of art dealers and mega-buyers, where insider information is the name of the game, Bouvier's case could be prove to be a game changer, as it potentially pits collectors against brokers, putting inherent conflicts of interest in the spotlight. At the same time, Rybolovlev is playing a high-stakes game, as a sophisticated collector and global businessman of his stature is not one who doesn't understand the risks he's taking. His lawyer claims other "victims" of Mr. Bouvier have already approached them, while the embattled King of the free ports believes he will clear his name in a Monaco court. Whatever happens the impact could be permanent.


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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