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 States back to suspected Rotenberg shell companies. This suggests that all 31 paintings were owned by the Rotenbergs.

When Mr. Baltser attempted to sell Brucke II in late 2018, both Christie's and Sotheby's expressed interest in having the painting at their auctions. Ultimately, Mr. Baltser's client chose Sotheby's to sell Brucke II at auction in February 2019. At the time, the Subcommittee was actively investigating the auction house and Mr. Baltser. Sotheby's requested Mr. Baltser provide the name of the UBO of the painting, including whether that individual was currently sanctioned. Mr. Baltser said Brucke II had been resold since it was purchased at Christie's in February 2014 and now belonged to a company incorporated in the Marshall Islands and provided a Russian passport for the company's UBO. The Subcommittee asked Sotheby's to request the name of the February 2014 purchaser of the painting; Mr. Baltser declined to disclose the name of that purchaser due to a non-disclosure agreement. Sotheby's ultimately pulled the painting from the 2019 auction due to a lack of interest.

The Subcommittee asked to interview Mr. Baltser, but through his attorney, he declined the request and stated he was in Moscow and had no plans to return to the United States. Through his attorney, Mr. Baltser stated that: he has never represented or transacted with Arkady or Boris Rotenberg; Highland Business and Highland Ventures were not listed as sanctioned by the Treasury Department; and he did not have access to the Panama Papers.

A delay between the 2014 announcement and imposition of sanctions created a window to send U.S. dollars to Russia. On March 16, 2014, President Obama signed an executive order authorizing the Treasury Department to impose sanctions on individuals for Russia's annexation of Crimea. But the Treasury Department did not name the specific individuals sanctioned under the executive order until March 20, 2014. During this four-day window, Rotenberg-linked shell companies transferred over $120 million through the United States to Russia. On March 18, 2014, Highland Ventures transferred over $39.5 million from its account at The Pictet Group in Switzerland through the U.S. financial system to its account at Gazprombank in Moscow. That same day, Culloden Properties transferred over $82