Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/66



Evidence examined by the Subcommittee suggests that the Rotenbergs used shell companies to mask their identities in transactions for high-value art both before and after being sanctioned by the United States. To form and manage those shell companies, the Rotenbergs appear to have used the services of attorney Mark Omelnitski and his company, the Markom Group. In addition, they also appear to have relied on art advisor and dealer Gregory Baltser, a U.S. citizen, to act as their representative in the art world to conceal their identities and involvement in particular art transactions, especially after becoming subject to U.S. sanctions.

Due to the lack of transparency in the art industry and in the formation and operation of shell companies, the evidence demonstrating the links between the Rotenbergs, their shell companies, Mr. Omelnitski, the Markom Group, and Mr. Baltser is not completely certain. Throughout the Subcommittee's investigation, witnesses interviewed by the Subcommittee claimed uncertainty and ignorance. One Sotheby's employee even told the Subcommittee she was untruthful to her employer when she previously stated that Mr. Baltser told her he represented Arkady and Boris Rotenberg. Regardless, the transactions outlined below represent the movement of millions of suspect U.S. dollars across international borders to purchase art, the investment of funds in U.S. assets with substantial rates of return, and a successful weakening of the impact of U.S. sanctions.

A. Attorney Mark Omelnitski and the Markom Group

Evidence suggests that the Rotenbergs were assisted in their efforts to evade U.S. sanctions by Mark Omelnitski, one of the founders of the Markom Group. Mark Omelnitski is a British citizen who was born in Moscow, Russia. The Rotenbergs reportedly used Mr. Omelnitski's services to set up a number of offshore shell companies.

In 2019, a Markom Group website identified Mr. Omelnitski as the Head of Compliance and Client Relations and a member of the Management Committee of the Markom Group. That website is no longer active and is only available through internet archives. On the archived website, Mr. Omelnitski was described as "a co-founder of Markom Group, Mark is Managing Director of Markom Management Limited, a founding company of the group. Mark is a member of a