In 2008, Elena Rybolovleva, Dmitry's wife of 24 years, whom he met on the first day at medical college back in Russia, filed for divorce, citing adultery on an industrial scale, including parties aboard yachts at which Dmitry shared "young conquests with his friends and other oligarchs." ("He was not a model husband," a spokesman for Dmitry later told the New York Times. "Mr. Rybolovlev never denied the infidelities, but the wife knew about it for many years and passively accepted it.") In the wake of what would become an exceptionally acrimonious divorce battle (which included Elena's being arrested in Cyprus for allegedly stealing a $28 million diamond ring she later proved her ex- husband had given her while they were still married), Dmitry began seeing art as an investment for his daughters' futures, he says. He subsequently started moving the collection into vaults (trophy works by Matisse, Klimt, Rodin, and Magritte by now had joined the stockpile). The art was owned by trusts, which, Elena complained, were designed to thwart her access to the couple's fortune in divorce court. The divorce (which, Dmitry confided exclusively to T&C, was finally settled in October for an undisclosed amount) was at one time famous for being the most expensive in the world, after a Geneva judge awarded Elena half of her ex-husband's fortune, some $4 billion.
Tetiana Bersheda warned me that I would find Tania Rappo "captivating." After I meet her in her lawyer's office, atop a creaking staircase in a building near the Fairmont Monte Carlo, and later at dinner, accompanied by her husband and her lawyer, at an outdoor French restaurant, I cannot deny it. Dressed casually in a black halter top, jeans, and heels—as well as big pearl earrings—Rappo looks far younger than her years. One of the first things she tells me—then repeats again and again—is that she and Bersheda never got along. Bersheda was always kept away from the art collection, and one senses how much the rivalry between these two women plays a role in the case.
The theory is that both sides would have something to gain. For Russian oligarchs and mobsters, there’s a need to launder money. “Generally speaking, the patterns of activity that we thought might be suggestive of money laundering were, you know, fast turnover deals and deals where there seemed to have been efforts to disguise the identity of the buyer,” Simpson told the committee in November. Trump, meanwhile, was in need of liquidity, because many banks were unwilling to do business with him after a corporate bankruptcy, and Russian buyers could provide quick infusions of cash. In other cases, the Trump Organization has appeared to have gone out of its way to avoid doing due diligence on business partners.

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:
Stories of art and money laundering tend to be media friendly, and often involve the wealthy behaving poorly.  In one notorious case, the Department of Justice (“DOJ”) seized, via a civil forfeiture action, Jean Michel Basquiat’s 1981 painting, Hannibal. This work — later returned to Brazil by the DOJ — had been smuggled into the U.S. by Edemar Cid Ferreira, a former Brazilian banker who was convicted of money laundering and other offenses, and who allegedly converted some of his laundered proceeds into a significant art collection.  According to the DOJ, although Hannibal had been appraised at a value of $8 million, it had been smuggled by Ferreira into the U.S. from Brazil, via the Netherlands, with false shipping invoices stating that the contents of the shipment were worth $100.  Other stories provide less genteel tales of drug cartels, terrorist organizations and other criminal syndicates financing themselves through systemic looting and the illicit antiquities trade.
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.
You need to use friends and trusted business associates and a willing collaborator at your desired destination to create a reliable bridge for turning your sanctioned or dirty money into sweet real estate so it can be liquefied when units are being sold or rented. Ideally, that collaborator needs to be in a bind and be willing to look the other way and not ask questions.
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.
“And this doesn’t just apply to the Russians. This is a general cultural thing whereby anyone with money is encouraged to come here. You can effectively buy residency. You’ve got non-dom status, which is very attractive, you’ve got the anonymous companies where beneficial ownership remains hidden, so to this day we have around 100,000 properties in this country whose owners are unknown.”
Of all the questions surrounding Trump and Russia, the question of whether the Kremlin could have laundered money through the Trump Organization in order to blackmail Trump has not often held the spotlight, obscured behind more direct connections, like discussions between Russian officials and Trump campaign officials like Donald Trump Jr. or George Papadapoulos, or more lurid ones from the Trump dossier.
But what we’re seeing is a pattern of Trump in the midst of wealthy foreigners engaged in money laundering schemes that center around real estate, and not bothering to vet any of them before doing business. Furthermore, there’s also the fact that he proudly claims to be the owner of more than 500 companies with very complex finances, which is a massive red flag in this context.

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.
In the interviews, Simpson is cagey about some of his business practices, and professes ignorance about the sources used by Christopher Steele, the former British intelligence officer who assembled the reports in the dossier. (Since lying to the committee would be a crime, it’s reasonable to assume his testimony is not deliberately false.) What’s most interesting is all the threads Simpsons mentions about possible Trump connections he’d reviewed with various Russians, with mobsters, and with others. For the most part, they’re just allegations: If Simpson has proof, it’s not disclosed in the transcripts. More often, they seem like tantalizing possibilities worth exploring more, but which Simpson was unable to nail down.
← The crate went through customs with a valuation of $100, though it contained Basquiat’s 1982 painting Hannibal (commodities valued under $200 aren’t required to be declared at customs.) The painting had been bought and shipped by Brazilian Banker Edemar cid Ferreira in an elaborate scheme to launder over $50 million that was illegally obtained when Ferreira’s bank, Banco Santos, went bankrupt.
"To put the mother of your two children in prison just not to give her money—what kind of person is that?" Rappo says. "This is the style of Mr. Rybolovlev, and that's exactly what happened to us. He wants to humiliate people and put such stress on them that they give up." (Rybolovlev brushes all this off and says Elena cannot stand to hear Tania Rappo's name.) I put it to Rappo: Why would Rybolovlev target her and Bouvier if not for the money he says they owe him?
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 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.
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.
In the shady world of art, private transactions are amongst the most opaque, which is exactly what this case is about. Bouvier, who takes credit in having built Rybolovlev’s collection into “one of the finest in the world,” admits to having worked with the oligarch for ten years, having sold him forty “major works,” reportedly from artists including Picasso, Gauguin, Degas, and even a controversial Da Vinci. Specifically, Rybolovlev’s family trust (which controls his collection) claims Bouvier defrauded them by taking a broker’s commission of 2% while charging an illegal, and hyperbolic, markup, using offshore companies to disguise his interventions.
At our meeting at La Belle Epoque I put it to him: Had he been conned or was he negligent? The answer, he explained, went back to the early 1990s, before he and his family fled Russia. After the fall of communism, Rybolovlev, who originally trained as a cardiologist, switched to finance and became one of the first securities traders in Russia. One of his first moves as a financier was to take a majority stake in Uralkali, the former Soviet fertilizer monopoly, which subsequently increased its productivity five-fold. Boris Yeltsin was president. The economy of Russia was melting down. The rule of law had all but disappeared, and Uralkali's success made Rybolovlev a target. To protect himself from ambushes he sent a fleet of identical cars with identical license plates registered in his name into Moscow; he also moved Ekaterina and his wife Elena to Geneva.
Besides that, there are other ways which an expensive art piece may be used to launder money. The underlying principle is this: there is no "standard answer" on how to launder money. Money laundering is more like an art than a science. As long as the whole process looks logical, reasonable and realistic, it is up to your creativity how you want to launder money with it!

The Russian investigation into Laundromat has been cursory. One investigator admitted his probe into RZB had stalled. Two FSB agents visited their counterparts in Moldova and collected documents. There are suspicions the FSB’s real goal was merely to find out how much investigators knew. In March, Moldova complained that in recent months Russian agents had been harassing Moldovan diplomats arriving in Russia.
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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