In the ongoing conflict between Russia and Ukraine, has long impacted the city of Kharkiv, but Russia's bombing this week struck the historic 13-story Derzhprom building, also known as the State Industry House, a symbol of architectural ingenuity that included overhead walkways and individual interlinked towers.  This iconic Soviet-era "skyscraper", located on the southwest side of Svobody Square, is not only a significant part of Ukrainian history but also represents the first modern skyscraper to be built in the city at the time when it was the capital of the Ukrainian SSR, one of the constituent republics of the Soviet Union from 1922 until 1991.

Derzhprom: A Glimpse into Soviet Architectural Heritage

Built between 1925 and 1928, with an opening timed to match the 11th anniversary of the October Revolution, the Derzhprom building is a hallmark of Constructivist architecture of that period.  Designed with a massive concrete facade, its stark lines gave the building an imposing silhouette —one that seemed to embrace minimalism, function, and mass production, all traits which reflected the Soviet ideals of efficiency, progress, and growth of the era.  

When completed, the architectural icon was once the tallest structure in the Soviet Union and Europe. 

UNESCO Status and International Protection

UNESCO has long recognised the historical significance of Derzhprom as being the largest constructivist building in the world and of significant importance for humanity.  The building was placed under its tentative UNESCO World Heritage list on April 27, 2017 in light of paragraph 32 of the Guidelines for the Implementation of the Second Protocol to the 1954 Hague Convention.

The non-military use declaration was signed by the Ministry of National Defense of Ukraine on 31 August 2023 stating that the cultural property “Derzhprom (the State Industry Building)” (Ukraine) would not be used for military purposes or to shield military or as a military site.  

Following this declaration, on September 7, 2023 UNESCO's committee included 20 of Ukraine's cultural heritage sites in the International List of Cultural Property UNder Enhanced Protection, among them, Kharkiv's Derzhprom.  This designation was a milestone in international recognition for Ukraine’s Soviet-era heritage, an highlighted Derzhprom not only as a building of local or national value, but also as a site of “outstanding universal value” reflecting UNESCO's commitment to safeguarding rare sites that contribute to shared human culture.  

Italy's Macerata prosecutor’s office has concluded its investigation into the theft of the painting The Capture of Saint Peter by Rutilio Manetti, seized in January.  As mentioned in our earlier blog post, this case has stirred significant controversy in Italy’s art world as it has implicated flamboyant art critic and former Undersecretary of State for Culture, Vittorio Sgarbi. 

Evidence presented in the expert report, including a forger’s confession, as well as an in-depth analysis of materials used on the canvas, points to Sgarbi's alleged involvement in forgery and laundering, putting him at risk of a serious prison sentence. 

The investigation, which drew national attention last January started as a journalistic probe by journalists working with Il Fatto Quotidiano and Report.  This later evolved into a full-scale inquiry where the former politician was formally named as a suspect in a case of theft, laundering, and art counterfeiting, for (it is alleged) his role in trying to conceal the true origins of the artwork.

A major development in the case was the discovery of a 250 ml tube of Cremnitz White paint, allegedly purchased from the famous Poggi artist supply shop in Rome, within walking distance of the Collegio Romano where Vittorio Sgarbi was Undersecretary of State for Culture. 

What's so special about Cremnitz White oil paint?

Lead white was the only white used in European easel paintings all the way until the 19th century when Titanium White was introduced.  Cremnitz White, a specific type of lead white made from lead carbonate (PbCO₃), is known for its warm, slightly yellowish hue, and is highly prized by Old Masters. 

Named after the Bohemian town of Kormeriz where this type of paint was originally produced and called Cremnitz while under Hapsburg rule, this lead paint has a unique, stringy consistency that distinguishes it from other lead whites. Unlike Flake White, Cremnitz White contains no zinc oxide, which means it dries more slowly but retains a smoother, more workable texture ideal for traditional painting techniques.

Pasquale "Lino" Frongia

The artist behind the forgery of The Capture of Saint Peter by Rutilio Manetti is said to be 66-year-old Pasquale Frongia, a friend of Sgarbi's.  Known to most as "Lino," Frongia has reportedly stated that he added a torch to the painting at the art critic's request—an addition to the painting not painted by Manetti's hand. 

Frongia is known across Europe as a remarkable and accomplished copyist and has twice faced European arrest warrants, in 2019 and 2023, based on forgery charges issued by the Paris court, though Italy has resisted his extradition to date.  In June 2023, the Carabinieri of Reggio Emilia arrested Frongia who stands accused of fraud and money laundering crimes.  

According to what has been stated by the French judicial authorities the forger would have created paintings on behalf of Emilian art merchant Giuliano Ruffini, who himself was extradited to France last December.  Ruffini is then alleged to have sold the paintings onward to museums in all of Europe, including the Louvre, attributing them to great painters.

Investigators believe that the Manetti artwork, stolen on 14 February 2013 from a castle in Buriasco, was altered either to increase its market value or to differentiate the painting, once handled by Sgarbi, from the one which had been reported as stolen.  

After going missing, the artwork resurfaced eight years later, displaye in an exhibition in the city of Lucca, I Pittori della Luce.  During this exhibition the painting was presented as coming from Sgarbi's personal collection and as having been found in an attic at the Villa Maidalchina, which in the 1600s was owned by Olimpia Pamphilij, sister-in-law of Pope Innocent, owned by the Sgarbi family since the year 2000.

Consultant to the Public Prosecutor's Office Barbara Lavorini who is a conservator for the Istituto Superiore per la Conservazione e il Restauro in Rome conducted photogrammetric surveys of the artwork, which included biological analysis of the painting's fibres, x-rays and multispectral analysis looking into what was believed to be a newly added torch, to determine if this detail was a recent addition or an original feature.

In her evaluation Lavorini writes: 

"As regards any modifications or additions to the original pictorial layout - the technical document states - it was possible to demonstrate that in the upper left part of the painting new elements were created with industrially produced pigments: the lit torch, the light around it and the layers that define the outline of the column".

Additional analysis also found signs of improper handling, suggesting that the painting was once rolled and stored improperly, perhaps damaged when the painting was stolen from the Castello di Buriasco and reported as stolen by Margherita Buzio as well as conditions compatible with the photos that showed it rolled up “like a carpet” the day it was delivered to Gianfranco Mingardi, one of Sgarbi's restorers, at the exit of the A4 motorway in central Brescia. 

For now, the legal complications for Sgarbi are serious. According to the Italian news site Il Fatto Quotidiano, Sgarbi's lawyer, Giampaolo Cicconi has been in contact with the attorney representing the owner of the stolen painting, which suggests that a settlement with her might be proffered as a means to get the artwork's owner to withdraw her civil action. 

If convicted, the €79 euro tube of paint may cost Sgarbi 4 to 12 years in custody, a hefty sum, for what some are now calling Vittó's little candle of disgrace.

Aside from the lighted torch element, which illuminates the architectural backdrop on the upper left side, the painting owned by the Cavallini Sgarbi Foundation is objectively identically proportioned character by character to the painting stolen from the Buriasco Castle.  

One could argue, as Vittorio Sgarbi has, that the stolen painting was a much later replica of his painting, however that still would not explain the absence/occurrence of the lit torch, and again, how the artisan who replicated the work would have precisely matched the brush strokes in such an extracting way. 

By: Lynda Albertson

In December 2019 Alejandro Corral, president of the Realejo neighbourhood association alerted the Environmental Prosecutor's Office of Madrid of a new attempt to sell stolen religious works of art from the church of the convent Nuestra Señora de Los Ángeles in the Realejo neighborhood of Granada.  In making his denouncement, Corral told the authorities that a17th century religious statue depicting Santa Rosa di Viterbo, by Baroque sculptor José de Mora, had been spotted in circulation on the religious art market, intentionally or unintentionally, labelled as Saint Margaret of Cortona in a catalogue titled "Seven Centuries of Spanish Art".  

This notice, in turn, triggered an investigation by Spain's Ministry of Culture and the Heritage Brigade of the Policía Nacional, code named Operación Granada.   Shortly thereafter, a social media outcry lead to researchers publicly naming the seller as Madrid-based art dealer Nicolás Cortés, who had included the statue in his gallery's Maastricht and New York sales offerings at TEFAF for €350,000.  

During the Spanish investigation, the National Police seized the 17th-century religious statue while still in the possession of Cortés, which effectively barred its sale onward, giving investigators time to clarify the statue's ownership and exportation details.

Interviewed by El Pais shortly after the news broke, dealer Nicolás Cortés told news services that he had bought the sculpture at the end of 2017 from an antique dealer for €100,000, stating he was told it came from a private collector.  These details were later determined to contain discrepancies.   Cortés is also quoted as saying “I wouldn’t think of going to a convent to buy because it’s illegal,”  and turned over the purchase invoice and the relevant export permit to the Spanish authorities conducting their investigation. 

Sister Josefa, the mother superior of the convent Nuestra Señora de Los Ángeles, initially claimed that the statue listed for sale by Cortés was different from the one in her order's church, citing the positioning of the left hand.  She also insisted that the convent still possessed its statue,  though admittedly, she initially declined to reveal its location. "There was never an image with that title in the convent," she told El País, suggesting the one for sale with the Madrid dealer as Saint Margaret of Cortona had simply been mistaken for the statue of Santa Rosa di Viterbo. 

Despite this, it was quickly determined that the statue in the religious order's possession was a crudely made modern fake, as can be seen in the image below.

Professor of history at the University of Granada, Lázaro Gila, who has also documented all the convents of Granada, told El País that he had no doubt that the figure for sale with Cortés' gallery was the Santa Rosa di Viterbo stolen from the church, adding that the artist de Mora did not produce the same sculpture twice.

Likewise, conservation experts were also convinced that the object for sale by the gallery was the stolen sculpture, given that the folds and design details of the mantle are quite specific and could not have been altered without risk of damage to the original polychromy.  The conservators also noted that the positioning of the hands could have been easily altered and that the Cortés’s gallery itself confirmed that the statue's left hand had been readjusted.

In December 2019, Spanish investigators determined that Alagón antique dealer Santos Boy Jimenez Borja had taken the 1.5 meters high, 17th century statue depicting Santa Rosa di Viterbo, which had been displayed above the church's altar, shortly after the convent's closure and around the same time other religious art objects from the closed convent began to appear on the Spanish market.  The object was purportedly removed, according to the religious order, on the pretext of obtaining an estimate for restoring it, only to have a replacement returned in its stead, commissioned to vaguely represent the polychrome saint. 

Jimenez Borja then sold the statuette to Cortés for an agreed value of 90,000 euros on 20 June 2018,  not in 2017 and not for the 100,000 euros as stated by the Madrid art dealer.  Equally unusual, to conclude thir sales transaction Jimenez Borja is purported to have received "45,000 euros through a transfer and a BMW X5 valued at the same price, although there were doubts about whether it was possible to export the piece given its religious origin."  So not exactly your routine sales transaction. 

On October 9th, the Court of Granada sentenced Jimenez Borja to four years in prison and handed him a fine of 3,650 euros for misappropriation of the eighteenth-century sculpture.   Despite his conviction, he still insists on his innocence, claiming he purchased the statuette directly from the religious order and reminding the Spanish news that he is not a restorer which makes the statements about removing the statue for a conservation estimate somewhat clouded. 

One we do know, is that cases like this one highlight the importance of precise record keeping and how a slight name change, or an intended disinformation strategy, can allow stolen material to circulate.  We don't fully know if the name manipulation on this statue was intentionally done to mask its identification, but we do know that Changing an artwork's attribution, is usually done with very specific reasons, usually involving intense study of a work or its identification in supportin literature.  In this case, we have no evidence of this type of scholarly research taking place.  As a result, a Spanish export license was issued for the statuette, despite the fact that it was clearly documented, complete with a photograph, in the registry of the Andalusian Institute of Historical Heritage, in charge of the protection and research on the historical heritage of Andalusia.   

Unfortunately, there the religious statuette is listed under the name Santa Rosa de Viterbo, not the name given on the export request, and registered as being in Sevilla, in the Municipality of Estepa at the Monasterio de Santa Clara de Jesús / Convento de Santa Clara.  Luckily the eyes of citizen activists played an important part in this artworks eventual recovery. 

For several years ARCA has followed the escapades of Raffaele Imperiale, one of Italy's most important (and violent) drug dealers, who admitted to purchasing two Van Gogh paintings stolen from the Van Gogh Museum.  This month, a new book, aptly titled Il Narcos, by Daniela De Crescenzo, a journalist for Il Mattino from 1981 to 2016 and part of the scientific committee of the magazine Narcomafie and Tommaso Montanino, an inspector with the Guardia di Finanza serving at the GICO in Naples explore in great detail, the life on the run of this once-fugitive Camorra affiliated boss.                                                                                                          In Il Narcos, the writers deliver an in-depth and riveting account of the rise and fall of Raffaele Imperiale, one of Italy’s most notorious drug traffickers. This true crime story takes readers from the rough streets of Castellammare di Stabia, where Imperiale was born, through a Naples dominated by feuding clans of the Camorra, and on to the glitzy excess of Dubai, where the drug kingpin evaded capture for years.

De Crescenzo skillfully traces Imperiale's path from his early years in organised crime to his eventual role as an international drug lord who dominated cocaine trafficking between Europe and South America for thirty years. And who, in order to obtain a reduction in his Italian sentence, handed over two Van Gogh paintings to the State in 2016 as well as the island of Taiwan, off the coast of Dubai, in 2023. 

Imperiale’s story is both a portrait of ambition and a chilling reflection of the global reach of the criminal underworld and this book’s strengths lies in its meticulous research.  Drawing on legal documents, police reports, and interviews the writers  construct a narrative that is comprehensive, yet still accessible to readers, vividly portraying not just Imperiale himself, but the entire ecosystem of crime and corruption that allowed him to thrive. 

The book also introduces readers to the intricate ties between Italian transnational organised crime groups, drug cartels, and political complicity, while never losing sight of the brutality and violence that Imperiale's operations left in their wake.  Throughout the book, the authors explore not only Imperiale's rise to power but also the societal conditions that enabled his success, providing insight into how economic disparity and the lawlessness of certain regions in Italy actively fuel the rise of figures like Raffaele, leaving us with an unsettling truth.  That sometimes crime does pay, if only for a time. And when it crumbles, it does so with devastating consequences—for the criminals, their families, and the societies that allowed them to flourish. 

Lastly, the book also covers the little talked about negotiations with agencies in the United States, citing that for six years, the FBI and the DEA negotiated conditions of collaboration, where, in exchange for help in framing the other leaders of the global drug cartel, the US would have guaranteed Imperiale a plea bargain for a lenient sentence for money laundering and, after a short period of detention, a new life in the United States, with his family and loved ones. 

This plan however was stalled when prosecutor of Naples Giovanni Melillo (now head of the National Anti-Mafia Directorate), removed the 'Imperial meatball' from the plate of the Americans.  All said, Il Narcos is more than just a biography of a single drug lord and the empires he built on violence and deception.  It is a stark meditation on the human cost of greed, corruption, and power.

By:  Lynda Albertson

Map from Oplontis: Villa A (“of Poppaea”) at Torre Annunziata, Italy. Volume 1. The Ancient Setting and Modern Rediscovery by John R. Clarke and Nayla K. Muntasser

Acting on a tip-off, the Carabinieri officers raided a cellar on Corso Garibaldi, number 106, just one minute's walk from the historic villa.  There the investigators  found three partially collapsed but still accessible tunnels, all leading in the direction of the Villa of Poppea, with its striking wall paintings  The officers also found a striking number of tools used for the illicit excavation, as seen in the video below.  These included aerators, shoring materials used in the tunnels' development, and containers already filled with volcanic lapilli removed during the advancement of the digging operation.

The owner of the cellar, a 53-year-old local carpenter with no prior criminal record, has been charged with conducting illicit works under Article 169 of Italy’s cultural heritage code. 

Investigators believe the tunnels were dug with the intent of reaching and stealing artefacts from the archaeological site, a UNESCO World Heritage Site known for its exceptionally preserved frescoes and structures dating back to ancient Rome.

The Villa of Poppea is a significant part of the Oplontis site and has long been a target for tomb raiders due to its rich archaeological significance. Authorities are continuing their investigation, focusing on whether the carpenter was working alone or, given the abitious nature of materials found, as part of a larger network of artefact thieves.

Earlier this month, a similarly ambitious illicit excavation was uncovered in the heart of Naples.  There officers discovered the remains of an 11th century medieval church eight meters below street level, 2 km away from Naples central train station near Piazza Bovio. 

The raider in this instance is a local entrepreneur, digging directly under an existing palazzo.  Recovered at the scene, officers seized some 10,000 archaeological fragments from the Roman and medieval eras, believed to be from the suburban sector of the ancient Magna Graecia city of Neapolis, as well as 453 intact archaeological finds from the Roman era , including: red-figure craters, amphorae, terracotta lamps and pipes, as well as Roman and medieval coins.

The previously undiscovered church is said to be a rare example of medieval art of the 11th century, whose decoration are similar t the nearby Sacello di Sant'Aspreno. 

Both incidences highlight the significant challenges posed by urban illicit excavations for both law enforcement and cultural heritage protection.  These unauthorised digs, often conducted covertly beneath residential or commercial properties, not only pose safety hazards due to unstable tunnels and potential structural damage, but they also risk irreparable harm to the archaeological context of the site. 

In cities with rich histories like Cairo, Rome or Naples, contemporary city expansion has often built over ancient treasures, making it difficult to monitor such hidden operations.   Looters seeking valuable artefacts frequently destroy layers of history, removing items from their context and severing crucial links to the past.  This not only deprives the public of valuable cultural knowledge but also fuels the black market for antiquities, undermining legitimate efforts to preserve and study historical sites. 

The challenge for authorities is compounded by the difficulty of detecting these operations in densely populated areas, where excavations can go undetected for years, beneath seemingly ordinary locations.

ARCA summers are pretty busy as each year.  Since 2009, the Association has hosted its multi-course Postgraduate Certificate Program in Art Crime and Cultural heritage which often means posting new developments in the art and antiquities crime sphere slow while we turn our attention towards trainees.  Now that the 13th edition of this annual PG Cert has concluded, we can take time to reflect on some of the summer's more interesting art and antiquities stories, two which involve the ancient art gallery, Phoenix Ancient Art.

More pieces, More Accusations

Back on the 15th of May, Gotham City, a French-speaking Swiss news website that focuses on white-collar crime reported that Ali Aboutaam, the Geneva-based ancient art dealer was again in hot water with the public prosecutor's office.  Despite his previous conviction in January 2023, where he received an 18-month suspended prison sentence,  Ali Aboutaam is again the focus of a new Swiss investigation.

According to the Geneva public prosecutor's office, Ali is alleged to have possessed two suspect alabaster (brucite) statues, representing a man and a woman, while, according to Gotham's reporting, he “knew that these cultural properties had been illicitly acquired during illegal excavations in Yemen”.  Assessed by art historians, at least one of the small statues is believed to come from an area located in the southern Yemeni plateau known for the immense Himyarite Kingdom .  The area is home to a large necropolis, Shuka, which dates to the 1st-3rd centuries CE and has been the focus of looting in varying periods.

Dat-Hamin Stele

In their research to prepare for their upcoming auction, Sotheby's staff discovered that the stele had been photographed and documented as a part of the Aden Museum's collection in Yemen.  The artefact had been looted in July 1994 during what is referred to as the Summer War, a civil war fought between the two Yemeni forces of the pro-union northern and the socialist separatist southern Yemeni states and their various supporters.  Relinquished by the dealers, U.S. Immigration and Customs Enforcement (ICE) ultimately seized the stele in September 2003, and the stela was officially signed over to the Yemeni ambassador in December 2004.

Following that civil war, Yemen implemented wider legal protections for its cultural heritage, although instability resulting from the present-day civil war continues to make enforcement difficult.  Law Number 21 of 1994 on Antiquities, as amended by Law Number 8 of 1997, is the primary law governing ancient sites and objects in the country.  

This law defines Yemen's “archaeological” materials; vests their ownership in the State, and controls their protection, conservation, restoration, and study.  It addresses aspects of ownership, permissions and obligations for archaeological work, introduces penalties for the illegal trade, and sets duties and guidelines on how to deal with discovered and excavated objects.  

As such, it will be interesting to evaluate what documents Phoenix possesses in support of their circulation of these two objects in Switzerland, which are presently of interest to that country's public prosecutor. 

Moving on to Taxes...

On 18 July 2024 Switzerland's Bundesgericht, the country's Federal Supreme Court in Lucerne issued several ruling impacting Ali Aboutaam.  Judgments 9C_107, 9C_184, 9C_187 and 203/2023 of 18 July 2024, issued by Federal Judges Thomas Stadelmann as the Presiding Judge, along with Judges Margit Moser-Szeless and Michael Beusch, rejected a series of complex appeals, made through the art dealer's attorneys, concerning outstanding tax assessments in relation to the importation of a group of antiquities, some housed outside the gallery and outside the Ports Francs et Entrepôts de Genève. 

In rejecting Aboutaam's appeals, the higher court's final rulings reaffirms that the Swiss-based brother has to pay approximately 3.5 million Swiss francs ($4,125,444.82) in outstanding value-added tax (VAT), as assessed by the Bundesamt für Zoll und Grenzsicherheit (Federal Customs Administration) and largely affirmed by the Federal Administrative Court.  Ali was also ordered to pay late interest payments totalling approximately 900,000 Swiss francs (another $1,060,995.36).

In November 2021, Aboutaam had originally handed a SFr 1.6m fine via Swiss customs, including the costs of the proceedings.  The tax authorities came after the antiquities dealer in that instance after Phoenix Ancient Art imported 37 million Swiss francs worth of antiquities into Switzerland between 2010 and 2017, but without paying the applicable VAT. 

Michel Van Rijn was born in Paris in 1950 and was a name that resonated through the corridors of the art world for all the wrong reasons.  His father, a Dutch dentist, owned a large collection of primitive art.  

Early in Michel's career, he veered away from the legitimate aspects of the business and into the shadowy world of illicit trade and forgery, and claimed to have made his first million in his 20s craftily smuggling icons out of Soviet Russia.  Over time, his life would become marked by a series of high-profile controversies, legal battles, and enigmatic actions that labelled him as both notorious and useful.

His career in art smuggling spanned several decades, during which he established himself as a formidable player in the art world.  His operations were diverse and far-reaching, spanning the global art market and involving the sale of everything from ancient artefacts, to religious, and contemporary works of art.  

As a dealer, Michel was willing to bend the rules, and was adept at exploiting the opaque nature of the art market in which he worked. As such, he was not opposed to using forged provenance documents and false histories to sell the plundered or counterfeit objects which passed through his hands. 

Van Rijn's relationship with law enforcement was complex, and often times contentious.  Facing multiple legal entanglements in several countries on charges ranging from smuggling to fraud, he nimbly managed to avoid prison sentences.  Likewise, his knowledge of the art market and its underground elements made him a valuable, if controversial, asset to investigators where he sometimes played the dual role of both criminal and an informant.  According to him, this position sometimes resulted in threats to his life and to his family members. 

Despite this, his legal cooperation led to the recovery of smuggled and stolen artworks, as well as the exposure of forgery rings, though many in the field consider his motives as self serving.  His informant status protected his interests and also served to out his misbehaving art market rivals. 

Despite, or perhaps born from his brushes with the law, Michel maintained a flamboyant public persona, cultivating a reputation that was equal parts charismatic rogue and master manipulator, a position he seemed to relish, alongside his new-found notoriety. On film, in several documentaries made about his exploits, he was blunt and brash with his opinions on how the art market really works. 

Later in life Van Rijn turned to writing, authoring several books and articles that provided rare glimpses into the murky world of art crime and which brought the general public's attention to the significant flaws in the system that governs the art trade.  Part autobiography and part exposé, Michel's writing detailed not only his own exploits but touched upon the broader issues of authenticity, smuggling, and the market's ethics or lack there-of.  This underscored the market's need for greater accountability.  While some praised his blunt and acerbic insights, others criticised him for being self-serving and for minimising his own skin in the game.

As a man who spent his entire career living in the grey areas of legality and morality, Van Rijn navigated his fame, as the spokesperson for the art world's underbelly, with a mix of charm, cunning, and audacity. Last week, on 25 July 2024, he died in Italy, still a figure shrouded in mystery and contradiction.   

To some, Michael Van Rijn was a necessary evil who helped shed light on the dark corners no one wants to explore within the high stakes game of buying and selling hot art.  To others, he was a Machiavellian manipulator who exploited his knowledge and his connections for selfish gains.  

Knowing a little bit about where and how Van Rijn lived in his latter years, I personally think his personal gain was short-lived and his death an estranged one. And while his methods and motivations are still being debated, there is no denying the impact Michel had on what we know about the crooked paths some objects travel, or the art market's dishonesty and cunning audacity, or the length some dealers go to exploit the market's loopholes and lax laws, and the often opaque nature of art transactions in the name of profit from ill-gotten gains.

By: Lynda Albertson