The United States passed the Banking Secrecy Act in 1970, requiring financial institutions to report certain transactions to the Department of the Treasury, such as cash transactions above $10,000 or any others they deem suspicious, on a suspicious activity report (SAR). The information the banks provide to the Treasury Department is used by the Financial Crimes Enforcement Network (FinCEN), which can share it with domestic criminal investigators, international bodies or foreign financial intelligence units.
In another common form of money laundering, called smurfing (also known as "structuring"), the criminal breaks up large chunks of cash into multiple small deposits, often spreading them over many different accounts, to avoid detection. Money laundering can also be accomplished through the use of currency exchanges, wire transfers, and "mules"—cash smugglers, who sneak large amounts of cash across borders and deposit them in foreign accounts, where money-laundering enforcement is less strict.

Scientific research is generally held to be of good provenance when it is documented in detail sufficient to allow reproducibility.[28][29] Scientific workflow systems assist scientists and programmers with tracking their data through all transformations, analyses, and interpretations. Data sets are reliable when the process used to create them are reproducible and analyzable for defects.[30] Current initiatives to effectively manage, share, and reuse ecological data are indicative of the increasing importance of data provenance. Examples of these initiatives are National Science Foundation Datanet projects, DataONE and Data Conservancy, as well as the U.S. Global Change Research Program.[31] Some international academic consortia, such as the Research Data Alliance, have specific group to tackle issues of provenance. In that case it is the Research Data Provenance Interest Group.[32]


Law enforcement officials in the United States and abroad say “Hannibal” is just one of thousands of valuable artworks being used by criminals to hide illicit profits and illegally transfer assets around the globe. As other traditional money-laundering techniques have come under closer scrutiny, smugglers, drug traffickers, arms dealers and the like have increasingly turned to the famously opaque art market, officials say.
Recent technology developments have aided collectors in assessing the temperature and humidity history or the wine which are two key components in establishing perfect provenance. For example, there are devices available that rest inside the wood case and can be read through the wood by waving a smartphone equipped with a simple app. These devices track the conditions the case has been exposed to for the duration of the battery life, which can be as long as 15 years, and sends a graph and high/low readings to the smartphone user. This takes the trust issue out of the hands of the owner and gives it to a third party for verification.
Once purchased, the art can disappear from view for years, even decades. A lot of the art bought at auctions goes to freeports – ultra-secure warehouses for the collections of millionaires and billionaires, ranging from Picassos and gold to vintage Ferraris and fine wine. The freeports, which exist in Switzerland, Luxembourg and Singapore, offer a variety of tax advantages because the goods stored in them are technically in transit. The Economist magazine reported that the freeport near the Geneva airport alone is thought to hold $100 billion (U.S.) of art.
Recent technology developments have aided collectors in assessing the temperature and humidity history or the wine which are two key components in establishing perfect provenance. For example, there are devices available that rest inside the wood case and can be read through the wood by waving a smartphone equipped with a simple app. These devices track the conditions the case has been exposed to for the duration of the battery life, which can be as long as 15 years, and sends a graph and high/low readings to the smartphone user. This takes the trust issue out of the hands of the owner and gives it to a third party for verification.
These pesky forgers don’t limit their scams to painting, and are capable of turning their hands to many types of fakery. In the case of this set of six Louis XIV chairs—sold by highly-respected Parisian antiques dealer Kraemer Gallery to the Palace of Versailles itself—it emerged after the sale was made public that there just were not as many chairs in the court of Versailles as there are currently in circulation. The natural conclusion would be that some of the presumed authentic chairs must indeed be fakes.

New England Glass Works (American, 1818-1888), Black-Amethyst Sinumbra Lamp, 1830-1835, Translucent dark amethyst glass appearing black, pressed, with patinated copper alloy (brass) fittings and iron alloy lamp mechanism, a blown transparent colorless glass shade, ground and wheel-cut, and a transparent blown glass chimney (replaced), 17 1/2 in., 2016.214.
   Redistribution of the world’s wealth after the Renaissance created an explosive demand for art by a newly educated and prosperous mercantile middle class. Guilds of Master artists and students became virtual factories for art that was produced to fill this demand. The sale of State and Ecclesiastical art collections created new secondary markets in the form of dealers, galleries and auction houses. For the first time in history, art became a commercial commodity.
No forgery to attain recognition is better known than the “Thomas Rowley” poems of Thomas Chatterton (1752–70), which the youthful author attempted to pass off as the work of a medieval cleric. These poems, which caused a scholarly feud for many years, were influential in the Gothic revival. Chatterton, however, enjoys a place in English letters as a creative genius in his own right. The more conventional forger William Henry Ireland (1777–1835) cheerfully manufactured Shakespearean documents until his forged “lost” tragedy Vortigern and Rowena was laughed off the stage at the Drury Lane Theatre, London, in 1796. More fortunate was Charles Bertram, who produced an account of Roman Britain by “Richard of Westminster,” an imaginary monk. Bertram’s dupe, the eccentric antiquary Dr. William Stukeley, identified the monk with the chronicler Richard of Cirencester, known to have resided at Westminster in the 14th century. Bertram’s forgery (cunningly published in a volume containing the works of two genuine ancient authors, Gildas and Nennius) had an enormous influence upon historians of Roman Britain, lasting into the 20th century. Equally influential were the Ossianic poems of James Macpherson (1736–96), which influenced the early period of the Romantic movement. To what degree Macpherson’s poems are to be regarded as spurious is not certain. Denounced in his own day they were possibly, as he claimed, based upon a genuine oral tradition of Scottish Gaelic poetry; but there can be little doubt that they were carefully edited and interpolated by their collector.
Jack Flam suggested the paintings be sent for scientific testing to Jamie Martin, one of the world's top forensic art analysts. Martin showed us how he examined one of the fake Robert Motherwells using a stereomicroscope to study every millimeter of the painting's surface, and to select and then remove samples for identification. That's how he detected circular marks in the base layers, indicating an electric sander had been used to remove paint.
Many works of art acknowledged to be authentic carry some risk that in the future questions of authenticity may arise. After all, experts sometimes change their minds, new experts may disagree with the old consensus, and new facts or technologies may emerge. An impeccable provenance that can be verified serves to mitigate that investment risk. On the other hand, we have seen that a dubious provenance may itself be used as circumstantial evidence that the work is a fake. Thus, even where authenticity is not currently an issue, an inaccurate or incomplete provenance still could give rise to a claim in the future.
Following these professional museum standards, TMA periodically reviews its holdings and occasionally deaccessions a select few works of art, based on what will enhance the entire Museum collection. The funds realized from deaccessioning are used solely to improve TMA’s collection through the purchase of new art, in compliance with the Association of Art Museum Directors (AAMD) Professional Practices in Art Museums (see here), the American Alliance of Museums (AAM) Code of Ethics (see the most recent update to AAM’s guidelines here) and the International Council of Museums (ICOM) Code of Ethics (see here).
The hardest deception to detect is usually one that has been made recently. The forgery is a product of the time in which it was made, and the forger is closer to current understanding of the artist or period forged. The forgery, therefore, is often more appealing than a genuine work of art. As a forgery ages, viewpoints and tastes shift, and there is a new basis of understanding. Consequently, a forgery rarely survives more than a generation.
Jack Flam suggested the paintings be sent for scientific testing to Jamie Martin, one of the world's top forensic art analysts. Martin showed us how he examined one of the fake Robert Motherwells using a stereomicroscope to study every millimeter of the painting's surface, and to select and then remove samples for identification. That's how he detected circular marks in the base layers, indicating an electric sander had been used to remove paint.
Any art object—paintings, sculpture, jewelry, ceramics, fine furniture, and decorative pieces of all kinds—can be forged. The difficulty of forging, however, is as important as market price in determining what is forged. Probably fewer than 1 percent of stone sculptures are false because they require so much labour to make and their market is limited, but as many as 10 percent of modern French paintings on the market may be forgeries. The technical difficulties in making a convincing imitation of an ancient Greek vase are so great that forgeries are almost nonexistent. In contrast the forgery level of tiny archaic Greek and Cretan bronze statuettes, which are simple to cast, is possibly as high as 50 percent. A forger is most likely to succeed with a mediocre piece in the middle price range because such a piece probably will never be subjected to definitive examination. Although the price should be low enough to allay suspicion, the object can still yield a fair return for the effort expended by the forger.

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.
During the Renaissance, many painters took on apprentices who studied painting techniques by copying the works and style of the master. As a payment for the training, the master would then sell these works. This practice was generally considered a tribute, not forgery, although some of these copies have later erroneously been attributed to the master.
Provenance can be difficult to determine. The information presented here is intended to be a teaching tool for those interested in provenance research, specifically how to read it and what to look out for in terms of periods and areas of added scrutiny. Beyond introducing readers to the subject, the page also aims to be the new home for information about the Toledo Museum of Art’s recently acquired works of art, especially those that require additional provenance research. The Museum welcomes any information from the public that may help close gaps or provide further information into the history of an object’s ownership.
* Get full names and contact information for all private parties who the seller claims previously owned the art, or other forms of proof that they indeed owned it. Confirm that these people actually exist (or existed) and, when possible, contact them or their descendants directly to confirm all claims. Or have the seller do it for you. Simply being given a list of names with no other accompanying or verifiable information is not enough.
The AML Standards for Art Market Operators (“AML Standards”) are set forth by the Basel Institute on Governance, an independent not-for-profit organization.  Not surprisingly, the AML Standards adopt a “risk based” approach to establishing measures to mitigate money laundering risks, and further note that “[s]mall businesses may not have the resources to address money-laundering risks in the same way that large auction houses or major dealers and galleries will have, and may have a different risk exposure.”  The AML Standards are intended to apply to everone trading in art objects, and intermediaries between buyers and sellers.  They also suggest that service industries supprting the trade in art objects that are already subject to AML laws, like financial institutions, should identify their clients and customers in the art trade “as higher risk as long as there are no internationally applicable standards.”
The ownership history of a work of art is of fundamental importance for all those involved in the collecting, exhibiting and study of art, for determining both attribution as well as legal title. Recent ownership claims by heirs of Holocaust victims whose art works were looted or otherwise misappropriated during the Nazi-era, and also claims by foreign “source” countries for objects they believe were exported in violation of patrimony or export laws, underscore the importance of provenance research. 
Whenever I am approached by someone to buy my art, who I did not know, I always insist that I be paid through PayPal or Payoneer. After that, I usually never heard from those people again.  Another way for an artist to protect themselves in a transaction like this is to insist to have the transaction handled by an escrow agent.  The final transaction, shipping etc. is not completed until all of the funds have been verified and cleared.  Any legitimate buyer or collector of art will not have a problem dealing in either manner.  Anyone who objects to this way of doing business with you is someone who you do not want to do business with!

I'll make a confession right off the bat: I didn't give The Art Forger 4 stars because I was blown away by the prose, scene, setting, or characterization. Had those been up to snuff I'd have given it an easy 5. There are some flat characters, relies somewhat on stereo typical thinking about artists and their studios, it sports some letters written by someone else in stand alone chapters which jar a bit with the first person view point (one would assume our heroine would have no knowledge of thes ...more
However, federal criminal prosecutions against art forgers are seldom brought due in part to high evidentiary burdens and competing law enforcement priorities. For example, internet art frauds now appear in the federal courts' rulings that one may study in the PACER court records. Some frauds are done on the internet on a popular auction websites. Traces are readily available to see the full extent of the frauds from a forensic standpoint or even basic due diligence of professionals who may research matters including sources of PACER / enforcing authority records and on the internet.
The dating of an object by the study of radioactive decay of carbon-14 has had little application in the detection of art forgery because of the large quantities of material that must be destroyed. Thermoluminescent dating is based on the slight damage to all matter, including clays, by the faint nuclear radiation present in the earth. Magnetic dating of ceramic objects is based on the slow but perceptible shift of the earth’s magnetic field over the centuries.
Let’s get back to the real estate pilot program that lies at the heart of the Times’s confusion. That federal program, which may or may not be continued, relies upon mortgage title insurance companies to report to authorities the ultimate beneficial owner of any vehicle used to buy or sell very valuable real estate. It does not require the seller to reveal the beneficial owner to the buyer or vice versa.
Fakes and forgeries in the art world are the stuff of legend, the subject of books, films, and television series the world over. In real life, they land people behind bars. 2016 brought us many unwanted things, but it also appears to have been a year when a huge amount of authenticity disputes took place. The spats took shape from contested provenance, to painters faking their own work, to a multimillion dollar Old Masters scandal. From farce to tragedy, we’ve compiled the highlights of this year’s biggest art forgery scandals below.
Under certain state laws the following statements may be required on this website and we have included them in order to be in full compliance with these rules. The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. Attorney Advertising Notice: Prior results do not guarantee a similar outcome. Statement in compliance with Texas Rules of Professional Conduct. Unless otherwise noted, attorneys are not certified by the Texas Board of Legal Specialization, nor can NLR attest to the accuracy of any notation of Legal Specialization or other Professional Credentials.
In the composite fraud, or pastiche, the forger combines copies of various parts of another artist’s work to form a new composition and adds a few connecting elements of his own to make it a convincing presentation. This type of forgery is more difficult to detect than the copy. Such a combining of various elements from different pieces can be very deceptive, because a creative artist often borrows from his own work. In fact, the similarity of a figure or an object in a forgery to that in a well-known work of art often adds to the believability of the new creation.
The wealthy figured this out in a big way back in the 1980s, giving rise to ‘art stars’ valued in the millions. And with the increasing popularity and geographical scope of biennials and art fairs in the 1990s, rich people all over the world now have access to seas of multi-million dollar investments that can be rolled up and stored just about anywhere.
While these laws were helpful in tracking criminal activity, money laundering itself wasn't made illegal in the United States until 1986, with the passage of the Money Laundering Control Act. Shortly after the 9/11 terrorist attacks, the USA Patriot Act expanded money-laundering efforts by allowing investigative tools designed for organized crime and drug trafficking prevention to be used in terrorist investigations.
This was the first book I read from the cache I purchased at the Miami International Book Fair. I wish I had a chance to read it before hearing B.A. Shapiro speak. After reading The Art Forger I am a fan. B.A. Shapiro gave a talk about her writing process with M.J. Rose, author of The book of Lost Fragrances, another novel I grabbed. I don't know if they were put on a panel together because they both go by their initials but it seemed a good pairing and their discussion was very insightful. I re ...more
They invented a story that fooled them all. Helene said her grandfather hid his art collection at his country estate in Germany before the war to protect it from the Nazis.  When he died, she said, she inherited it.  But there was nothing to inherit, because there had never been a collection. Every one of the works had been painted by Wolfgang Beltracchi.

Founded in 1901, the Toledo Museum of Art holds a collection of extraordinary artworks. We are a free museum that had nearly half-a-million visitors last year and is nationally renowned for its focus on art education. Even with those distinctions, the Museum is most notable for the quality of its collection. Aside from its comprehensive collection of glass—Toledo is known in America as the Glass City—TMA has never sought to be comprehensive in its approach to collecting—the institution’s focus has been and remains on singular artworks by singular artists. Quality has always been the outstanding attribute of our collection, and the objects being sold are not of the quality of our permanent display collection; have been on display rarely; have not been sought out by scholars; or have not been published in recent decades. In short, these objects were not working to fulfill our mission.


Provenance trials, where material of different provenances are planted in a single place or at different locations spanning a range of environmental conditions, is a way to reveal genetic variation among provenances. It also contributes to an understanding of how different provenances respond to various climatic and environmental conditions and can as such contribute with knowledge on how to strategically select provenances for climate change adaptation.[68]
At times restoration of a piece is so extensive that the original is essentially replaced when new materials are used to supplement older ones. An art restorer may also add or remove details on a painting, in an attempt to make the painting more saleable on the contemporary art market. This, however, is not a modern phenomenon - historical painters often "retouched" other artist's works by repainting some of the background or details.
Of course, beyond AML-related process concerns, any art dealer — just like any business person — always must remember that just about any financial transaction that involves proceeds known to have originated from illegal activity represents a criminal money laundering offense.  Stated otherwise, even if the BSA is not expanded to include dealers in art and antiquities, those in the U.S. art industry still need to bear in mind, in extreme examples, the omnipresent federal criminal code.  Sometimes, the provenance of the funds can be more critical than the provenance of the art.

Where the research is proceeding backwards, to discover the previous provenance of a painting whose current ownership and location is known, it is important to record the physical details of the painting – style, subject, signature, materials, dimensions, frame, etc.[7] The titles of paintings and the attribution to a particular artist may change over time. The size of the work and its description can be used to identify earlier references to the painting. The back of a painting can contain significant provenance information. There may be exhibition marks, dealer stamps, gallery labels and other indications of previous ownership. There may also be shipping labels. In the BBC TV programme Fake or Fortune? the provenance of the painting Bords de la Seine à Argenteuil was investigated using a gallery sticker and shipping label on the back. Early provenance can sometimes be indicated by a cartellino (a representation of an inscribed label) added to the front of a painting.[8] However, these can be forged, or can fade or be painted over.

Mr. Ellis serves as Director of Business Development and Marketing of AML RightSource. He has over 15 years of experience in business development, marketing, and professional consulting within the healthcare and financial services industries. Mr. Ellis earned his undergraduate degree from Bowling Green State University and obtained his juris doctor from Cleveland State University – Cleveland-Marshall College of Law.
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.”
There is no comparable entity in the art market. But were the same type of program instituted in the art market, it would only require that the auction house, dealer or lawyer know the beneficial owner and be able to reveal that information to federal authorities. It would not require the other side of the transaction to learn the seller (or buyer’s) identity.
All the paintings appear to have originated with one man, an obscure French collector-turned-dealer named Giulano Ruffini. The works appear to have had next-to-no provenance, save that they came from the collection of French civil engineer André Borie. Ruffini insists he never suggested they were the real deal, and that eager dealers were the ones to declare his paintings Old Master originals.
“There are museums in the past who have wanted to take something of high value down and replace it with a replica, but that’s a behind-the-curtain thing,” says Timothy Carpenter, a supervisor and special agent in the FBI’s art theft program who frequently lectures collectors to do the same. “If you’ve got this $10 million painting that you’re concerned about, you can probably afford to make a $5,000 copy made and hang it. It’s the only guarantee to keep their painting safe if they don’t have security on their residence.”
Though there are no hard statistics on the amount of laundered money invested in art, law enforcements officials and scholars agree they are seeing more of it. The Basel Institute on Governance, a nonprofit research organization in Switzerland — the site of the world’s premier contemporary and Modern art show — warned last year of the high volume of illegal and suspicious transactions involving art. But regulation has been scattershot and difficult to coordinate internationally.
Despite those advances, the detection of fraudulent art remains a complex undertaking. It is particularly difficult to weed out forgeries in the work of modern artists whose large numbers of works and superstar statuses make them especially attractive to those who commit fraud. Pablo Picasso, for example, was a prolific artist, creating a huge number of works on canvas and on paper as well as sculptures and ceramics. Considering his vast output and the varying styles and media in which he worked, scholars have had difficulty establishing a definitive corpus for him. The prestige associated with owning a Picasso and the difficulty of attribution, especially for a drawing, made and continues to make fraudulent representations of his work hard to police.
×