Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/34

 Langvik Congress Wellness Hotel to his son Roman. The Rotenbergs described the sales as nothing more than a long-planned "generational change."

i. Roman Rotenberg

In response to the transfers described above, on July 30, 2015, under EO 13661, OFAC added Roman Rotenberg to the list of sanctioned individuals. A Treasury press release noted Roman Rotenberg was "linked to the provision of material support" to Boris Rotenberg.

'''ii. Igor Rotenberg'''

On April 6, 2018, three years after sanctioning Arkady and Boris Rotenberg, OFAC also sanctioned Arkady's son Igor. This round of sanctions targeted Russia's so-called "golden youth" and also included sanctions against Putin's son-in-law Kirill Shamalov. Just prior to OFAC's imposition of sanctions, Forbes included Igor Rotenberg on its list of 259 new billionaires. OFAC's announcement of the new sanctions credited Igor's designation to his activities in the Russian energy sector, noting that Igor had acquired significant assets from his father post-sanctions.

From 2002 to 2003, Igor Rotenberg served as the deputy head "of the Property Department of the fuel and energy complex of the Ministry of Property and