where Rybolovlev was informed that the Kremlin was reopening a potentially bankrupting investigation into the collapse of a mine belonging to Uralkali. Understanding the government's interest in his company and that his days of owning it were numbered, Rybolovlev cashed out, leaving his estimated net worth somewhere between $8 billion and $13 billion. He then focused on trolling the world for other investments. In 2010 he moved to Monaco, his trusts buying La Belle Epoque. His trusts also bought a majority stake in the AS Monaco soccer team in 2011. And in 2012 a broker recommended by Rappo sold his trusts the penthouse at 15 Central Park West. Rybolovlev says that Rappo called him as the deal was closing. "I've been offered a commission of $100,000," she told him. "Would you mind if I accepted?"
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.
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.
Briefly: On New Year's Eve 2014, Rybolovlev found himself at the Eden Rock St. Bart's eating with Sandy Heller, a New York art consultant who advises many hedge fund managers. Somewhat obliquely Heller said, "It looks like you bought the Modigliani [we sold]." He was referring to Reclining Nude with Blue Cushion, one of the artist's most famous canvases, painted in 1917. The painting had belonged to Steven A. Cohen, the founder of SAC Capital Advisors and also one of the richest men in the world.
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.
Finally, he also failed to vet his partner in Trump Scion hotel opening soon in Dallas, who has deep ties in money laundering from Kazakhstan and Russia, and opened two offshores in Cyprus in 2008, which, again, is the favorite destination for Russian oligarchs’ exported cash. (The Scion deal ultimately fell apart due to public opposition to the project.)

— The United Nations Office on Drugs and Crime estimates the amount of illicit money that is laundered each year to be between “2 - 5% of global GDP, or $800 billion - $2 trillion in current US dollars.” The difficulty of knowing exact figures accounts for the huge margin within estimates. The UN’s estimates specifically cite “Mega-Byte” as an issue, defining the term as “money in the form of symbols on computer screens the can move anywhere in the world with speed and ease.”
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“I've felt all along in the Russia investigation that the most important issues were those that had the potential of exerting a continuing influence over the administration and over U.S. policy,” Representative Adam Schiff of California, the ranking Democrat on the House Intelligence Committee, told me Friday. “And if the Russians were laundering money through the Trump Organization, the Russians would know it, the president would know it, and that could be very powerful leverage.”
In one current money-laundering case, United States authorities have accused Malaysian officials and associates in a civil complaint of converting billions of dollars of embezzled public funds into investments like real estate and art. Masterworks by Basquiat, Rothko, Van Gogh and others were purchased, many at Christie’s, according to a complaint filed by federal prosecutors. Later, a Cayman Island company owned by one of the accused launderers took out a $107 million loan from Sotheby’s in 2014 using some of those artworks as collateral, authorities say.

The bank bought an $850 million stake in a Ukrainian steel mill through a mystery middleman, then sold it to Russian-Canadian investor Alexander Shaider. This investor who would then fund Trump International Hotel and Tower in Toronto, and pay the consulting and licensing fees to label it a Trump property and bring it under The Donald’s umbrella in the public eye. In fact, this is how Trump’s name ended up on so many buildings. It’s licensed while its true owners are out of sight, and out of mind.
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.)
Oh fuck yes! Look, I'm not a conspiracy theorist, but the art market is a billion-dollar industry. If it [smuggling] is not tolerated on certain levels, the banks would never reach their peaks. I had people on my payroll at customs... it was barely even necessary to smuggle because you could bring it in almost officially so long as you pay a little bit to the right people.
Consistent with general AML principles, the AML Standards stress that beneficial ownership may be obscured behind multiple layers of intermediaries, such as shell companies or offshore companies involving trusts. The AML Standards further provide a list of possible red flags for identifying increased risks of money laundering presented by a client that:
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