"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."
Creating and maintaining hundreds of LLCs to ostensibly do the same thing, like build hotels, condos, and homes, adds millions in bureaucratic overhead from payroll to tax filings. It wouldn’t be an issue if Trump ran a dozen corporations specializing in each vertical of his business, so having multiple companies under one umbrella is not at all unusual. Having so many doing the same things, however, is typically the same kind of warning sign for money laundering as being constantly told to recruit new salespeople is to pyramid schemes.
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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.
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.”
According to Bersheda, the criminal complaint she filed last year was against Bouvier only. Rybolovlev was already hurt and angry, but the serious pain came, he says, when he heard that investigators had found commissions from Bouvier in Rappo's bank accounts going back to 2004. Rappo knew Rybolovlev to be reserved and wary, he says. He let his guard down around Bouvier because he trusted her. At that point he began to see Rappo, not Bouvier, at the center of the spider's web. Their falling out has led him to ask what he calls "difficult philosophical questions." Had it not been for the dentist's wife he would never have gotten involved with Bouvier.
Buried treasure, mysterious deaths, looting, forged documents, secretive Swiss bank vaults and shadowy intermediaries. This is not a description of a Dan Brown thriller. It’s real life: the trade in illegally exported antiquities. As prices soar into the millions of dollars for the top pieces, so does the incentive to dig up treasures in Italy, Greece, Turkey and farther afield, pass them to “runners” who will sneak them illegally across borders, store them in a Swiss vault and then quietly slip them into the trade. The players in this murky world can make a fortune, but this is a dangerous game.
According to former art consultant Beth Fiore, people don’t normally buy art with cash in the US; “Cash payments for art happen in Russia [and the] Middle East” more often. So if you’re keeping your fortune under your mattress and don’t live in either of those places, you’ll need to get your money into a bank account without alerting the authorities. One way to do that is by smurfing. Despite the mental image of a blue cartoon character riding a surfboard that you may have conjured, smurfing means depositing money into a bank account or several bank accounts by breaking it up in to many small amounts that are deposited at different times, by different people. US banks must report any deposits over $10,000 to the IRS, so in order to stay sneaky, you’ll need to make a series of deposits that are less than that amount. You can hire “smurfs” to help you, who are often ordinary people willing to make an extra buck by opening up a joint bank account in their name, that you or your company has access to, and depositing money into it every day.
The Art Business should examine the client’s background and purpose behind the contemplated transaction. For example, are the artworks being sold by the client consistent with what is known about the client’s collection? Is the level at which the client is selling or buying consistent with their past transactions and what is known about their professional activities and personal wealth? If not, the Art Business may want to ask the client for further information.
Tucked behind Kensington Palace and protected by armed police at checkpoints on either end is the street known as Billionaire’s Row, the most expensive in London and perhaps the world. A private road owned by the Crown Estates, traffic is light and slow here, and a prohibition on photography is enforced by the private security guards who watch over every other house.
But his suspicion was not triggered until Bouvier came to Rybolovlev in 2013 and 2014 to shop two paintings, first Salvator Mundi, a recently discovered Leonardo for which he wanted $127 million, and then No. 6 (Violet, Green and Red), a prized Rothko for which he requested $140 million. Rybolovlev told Bouvier that the family trusts would pay for the Rothko only in installments while Bouvier sold other works, including a Modigliani sculpture Rybolovlev had owned since 2012. Bouvier seemed to have trouble finding a buyer for the Modigliani—or "anything!" Rybolovlev says.

“Before we looked into the allegations that Trump campaign people were surreptitiously meeting with the Russians it was only an allegation, but it proved to be all too true,” Schiff said. “Before we looked into allegations that Mike Flynn was having secret communications with the Russians and that the Trump transition might be seeking to undermine the sanctions imposed on Russia over its interference to help the Trump campaign, that was only an allegation, but that proved to be true. There's simply no way to either verify or be able to dismiss these serious allegations without looking into them.”
Price flexibility in the art world is just one of the many advantages for a certain subset of the criminals — money launderers. Other advantages include portability, lack of a paper trail, anonymity, and no regulations. Artwork is lightweight compared to other valuables, like gold and cash. Artwork is bought and sold with minimal paperwork, unlike real estate. Artwork purchases can be anonymous, unlike everything else.
The Italian and other governments are becoming far more aggressive in seeking the repatriation of looted antiquities. Italy in particular waged a long legal battle against Getty curator of antiquities, Marion True, for acquiring illicitly exported pieces, although the case finally exhausted the statute of limitations. And in recent years numerous American museums – including the Metropolitan Museum of Art in New York, Boston’s Museum of Fine Art and the Getty in Los Angeles – have been forced to return looted antiquities to their host countries. These include the famed Etruscan Euphronios krater (wine bowl) dating from 515 BC and which was bought by the Met in 1972 for $1.2m. It turned out that this had also been handled by Medici, and the museum gave it back to Italy in 2006. Just this month, the Getty said it was returning a 12th-century Byzantine illuminated New Testament to the Greek Dionysiou monastery – from which it had disappeared more than 50 years ago.

The potential role of high-end art and antiquities in money laundering schemes has attracted increasing attention over the last several years, particularly as the prices for such objects steadily rise and a tightening global enforcement and regulatory net has rendered other possible avenues for money laundering increasingly less attractive. The effort to subject U.S. dealers in art and antiquities to Anti-Money-Laundering (“AML”) obligations recently has gained new life.  As we blogged, the House Financial Services Committee just released three proposed bills to codify many of the reform ideas that have been swirling around the Bank Secretary Act (“BSA”) and AML and Combating the Financing of Terrorism (“CFT”) laws.  One of the bills — entitled as the “To make reforms to the Federal Bank Secrecy Act and anti-money laundering laws, and for other purposes” —  catalogues various detailed provisions seeking to reform the BSA and AML laws.  Nestled admist all of the other, generally higher-profile proposals (such as the creation of a BSA whistleblower program), one short section of this bill simply expands the list of defined “financial institutions” covered by the BSA to include “dealers in art or antiquities,” and then states that the Secretary of the Treasury shall issue implementing regulations within 180 days of the bill’s enactment.
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