"I think I can be useful," Rappo says Bouvier told her. Rybolovlev "jumped," she says. "He was really very happy." According to her, the oligarch recognized that Bouvier had some of the best art in the world sitting in his Geneva warehouse. Rybolovlev, for his part, says he scarcely remembers his first meeting with Bouvier, and he took the meeting only because Rappo encouraged him to. He found Bouvier "a regular, likable man," different from the stereotypical smooth-talking art dealer. And because Rappo, whom he trusted "totally," had brought them together, Rybolovlev agreed to work with him for, the oligarch claims, a fee of 2 percent—which Bouvier denies, saying that amount was merely for transport and administrative costs.
Look, I've been shot at on three separate occasions, I've had guns on my head, I've had police chasing me... To survive I have been a chameleon. As you know, I speak many languages. Also, I'm not attached to anything. It's like living near a fault line-if you hear a noise, pack your things and get the fuck out of there. Don't become too accustomed to anything. I can sleep like a baby on a little field bed.
On April 2nd, the New Directions in Anti-Kleptocracy Forum, organized by the Harriman Institute at Columbia University, will identify emerging issue areas relating to kleptocracy. I am excited to be serving as a co-panelist on the forum’s Art Market as a Node of Kleptocracy panel, which will discuss beneficial ownership and the luxury art market. Money Laundering Watch recently addressed the relationship between art and money laundering, a topic of growing interest.
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He returned in 1996, trying to build yet another hotel in partnership with a tobacco company. That deal also went nowhere, but Trump was able to successfully apply for Trump Russia trademarks. Ultimately, he never built anything there, but by the early 2000s, his units were suddenly a hit with wealthy Russians. His properties in Florida and NYC are especially popular, with Russian real estate agent Ilya Reznik telling the press that Coastal Miami is often pitched as Little Moscow.

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.


Chagall's Le Grand Cirque was stored in the Geneva free port, and Rybolovlev took Rappo with him to view it. Rappo has since said that she remembers that Bouvier appeared in person to greet them and was attentive. Rybolovlev claims to barely recall this. "If he had approached me, I would not have wanted to know him," he says, citing his habit of shying away from anyone trying to solicit his business.
For the next few years Rappo's relationship with Rybolovlev was status quo. It was not a friendship, she says: "I had affection for her. I never had affection for him... He's a block of ice." However, she continued to be a liaison between Rybolovlev and Bouvier; and she continued to receive introduction fees from Bouvier, an arrangement for which she says she received around 5 percent whenever a deal closed. She and Elena stopped speaking for a reason Rappo won't divulge.

Meanwhile, Trump was exploring a foray into reality TV about a St. Petersburg-based MMA fighter and his son, Donald Trump Jr., told the media that “Russians make up a disproportionate amount of Trump assets,” a claim his brother Eric would take even further in 2014 when he said that Trump has “all the money [he] needs from Russia” and cited golf-loving oligarchs investing over $100 million in the family business. Eric would later deny he ever said any such thing, playing into his father’s campaign against “the lying media and its fake news” when this story was dug up earlier this year by journalists.


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:
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.

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.”
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In regards to the critical issue of the source of the funds, the AML Guidelines “encourage” art businesses “to decline payments from a third party who is not their client and buyer of record. If there are legitimate reasons why it is justified for the Art Business to accept payment from a third party, before doing so the Art Business should conduct enhanced due diligence on both their buyer of record and the third party payer[.]”  The AML Guidelines also articulate a “preference” for art businesses only “to accept payments from reputable banks in jurisdictions subject to AML regulation and supervision.  Such reputable banks and financial institutions are generally subject to a high degree of AML regulation. That said[,] Art Businesses should remain vigilent and not rely entirely on the fact that banks and financial institutions will have carried out the necessary checks and verification to be satisfied that the source of funds is clean.”
I'm not going to bullshit you. Single shipments from Russia were between one and three million, which in the 60s was a lot of money. And these were regular trips-twice a month. It was raining money so I made my base in Beirut. Moneywise Beirut was a free banking market, so you could exchange a million dollars completely open on the square and no one would ask any questions. Of course you had to play the cat and mouse game with Interpol.
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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"It's easy for [Bouvier and Rappo] to paint me as the stereotypical Russian oligarch," he says. But if he were so interested in hiding his assets from Elena, he says, why would he announce to the world that he had been the victim of a multibillion-dollar scam, in the process letting it be known how much his trusts had overpaid for each of his artworks?

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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