GLOBAL FINANCIAL CRIME REVIEW
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Graham Bowley , “ As Money Launderers Buy Dalís , U . S . Looks at Lifting the Veil on Art Sales ,” The New York Times , June 22 , 2023 , https :// www . nytimes . com / 2021 / 06 / 19 / arts / design / money-laundering-art-market . html
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Whereas sanctions regimes have been criticized for inefficiency or for harming ordinary citizens more than government officials , when sanctions are well-designed and tailored to an individual or sectors of the economy they can exert pressure on sanctioned persons by excluding them from the global financial system and restricting their movements . While the sanctioned individuals have a harder time securing services , including legal services , the legal system may provide opportunities to appeal sanctions .
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Christian Duvernoy , Michael Dawson , Ronald I . Meltzer , et al ., “ The Emergence of a Global Russia Sanctions Enforcement Regime ,” WilmerHale , April 27 , 2023 , https :// www . wilmerhale . com / insights / client-alerts / 20230427-the-emergenceof-a-global-russia-sanctions-enforcement-regime
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Taylor Dafoe , “ Major U . S . Auction Houses Have Reportedly Been Subpoenaed as Part of a Federal Investigation Into Sanctioned Russian Oligarchs ,” Artnet , February 3 , 2023 , https :// news . artnet . com / art-world / us-auction-housessubpoenas-russian-oligarch-investigation-2251085
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Adam Taylor , “ Want to rein in Russian oligarchs ? Target the wealth managers , study says ,” The Washington Post , March 7 , 2023 , https :// www . washingtonpost . com / world / 2023 / 03 / 07 / russia-oligarchs-sanctions-offshore /
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Examples of wealth and their trajectory include the following : Caroline Freund , “ Rich People Poor Countries : The Rise of Emerging-Market Tycoons and Their Mega Firms ,” Peterson Institute for International Economics , 2016 , https :// www . piie . com / bookstore / rich-people-poor-countries-rise-emerging-market-tycoons-and-their-mega-firms ; “ Vekselberg , Victor Feliksovich : Businessman , Owner and President of Renova Group and head of Skolkovo Technology Park ,” RussiaProfile . org , June 22 , 2010 , https :// web . archive . org / web / 20130824210730 / http :// russiaprofile . org / bg _ people / resources _ whoiswho _ alphabet _ v _ vekselberg . html
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Please see the War & Sanctions portal for the names of the different individuals who are sanctioned in different jurisdictions : https :// sanctions . nazk . gov . ua / en /
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“ Luxury Goods : Frequently Asked Questions — As of July 26 , 2023 ,” European Commission , https :// finance . ec . europa . eu / system / files / 2023-07 / faqs-sanctions-russia-luxury-goods _ en . pdf
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Abramovich reportedly transferred $ 4 billion into trusts for the benefit of his children weeks before the full-scale invasion of Ukraine in February of 2022 . Please see : Harry Davies , “ Leak reveals Roman Abramovich ’ s billion-dollar trusts transferred before Russia sanctions ,” The Guardian , January 6 , 2023 , https :// www . theguardian . com / world / 2023 / jan / 06 / roman-abramovich-trusts-transfer-leak-russia-sanctions
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Oligarch Alisher Usmanov , sanctioned in early 2022 , reportedly filed for divorce in June 2022 and agreed to give all his assets to his wife of 30 years of marriage ; Anna Bondarenko , “ Fictitious divorce of oligarch Usmanov / Фиктивный развод олигарха Усманова ,” KAPOTECA , June 13 , 2022 , https :// kartoteka . io / news / 9606-fiktivnyj _ razvod _ oligarha _ ucmanova
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Ava Benny-Morrison , “ Rich Russians ’ Art Buying Is Target of US Crackdown on Trade-Sanction Cheats ,” Bloomberg . com , February 1 , 2023 , https :// www . bloomberg . com / news / articles / 2023-02-01 / hunt-for-sanction-cheats-targetsart-buying-by-rich-russians
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“ S . 2066 — Sanctions Evasion Whistleblower Rewards Act of 2023 ,” Congress . gov , June 21 , 2023 , https :// www . congress . gov / bill / 118th-congress / senate-bill / 2066 / text ; “ H . R . 4234 — Sanctions Evasion Whistleblower Rewards Act of 2023 ,” Congress . gov , June 21 , 2023 , https :// www . congress . gov / bill / 118th-congress / house-bill / 4234 / text ; Note : There is nothing art specific here , but it would apply to art agents , dealers and advisers .
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“ U . K . Businessman Graham Bonham-Carter Indicted for Sanctions Evasion Benefitting Russian Oligarch Oleg Vladimirovich Deripaska ,” U . S . Department of Justice , October 11 , 2022 , https :// www . justice . gov / opa / pr / uk-businessman-graham-bonham-carter-indicted-sanctions-evasion-benefitting-russian-oligarch
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“ Treasury Releases Study on Illicit Finance in the High-Value Art Market ,” U . S . Department of the Treasury , February 4 , 2022 , https :// home . treasury . gov / news / press-releases / jy0588 ; “ Six Individuals And Four Corporate Defendants Indicted In $ 50 Million International Securities Fraud And Money Laundering Schemes ,” U . S . Department of Justice , March 2 , 2018 , https :// www . justice . gov / usao-edny / pr / six-individuals-and-four-corporate-defendants-indicted- 50-million-international
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Free ports have been identified as a potential factor for money laundering . This is due to their unique legal and regulatory status , which allows for the storage of goods without the need for customs checks or taxes . Since these items are considered to be just transiting through , they have not technically entered that country and so cannot be taxed . Please see : Kenza Tahri , “ Luxury Freeports and Crime : What are the Risks ?” Center for Art Law , September 3 , 2022 , https :// itsartlaw . org / 2022 / 09 / 03 / luxury-freeports-and-crime-what-are-the-risks /
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“ Money Laundering ,” United Nations Office on Drugs and Crime , https :// www . unodc . org / romena / en / money-laundering . html
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“ Manhattan U . S . Attorney Announces Return To Brazil Of Two Masterpieces Linked To Bank Fraud ,” United States Attorney ’ s Office , Southern District of New York , June 18 , 2015 , https :// www . justice . gov / usao-sdny / pr / manhattan-us-attorney-announces-return-brazil-two-masterpieces-linked-bank-fraud
130 acamstoday . org