Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/70

 told the publication: "All our clients' dealings are bona fide transactions in accordance with the law."

1. The Markom Group Established Rotenberg-linked Shell Companies

In spring 2016, the International Consortium of Investigative Journalists ("ICIJ") published information related to a collection of over 11.5 million documents originating from the Panama-based law firm of Mossack Fonseca & Co. ("Mossack"). The documents spanned a more than thirty-year period from 1977 to 2015. ICIJ disclosed that Mossack was "one of the world's top creators of shell companies, [which are] corporate structures that can be used to hide ownership of assets." ICIJ explained that the Mossack documents consisted of files that "contained information on 214,488 offshore entities connected to people in more than 200 countries and territories." ICIJ also disclosed that the documents included "emails, financial spreadsheets, passports and corporate records revealing the secret owners of bank accounts and companies in 21 offshore jurisdictions, from Nevada to Singapore to the British Virgin Islands." Those Mossack documents became known as the "Panama Papers."

Rotenberg-related BVI companies. The Panama Papers included an email chain made public by ICIJ and dated August 27, 2010 from Helen Okell at Mossack to Dorota Skowronska at Mossack with a copy sent to Mark Omelnitski under the subject line "BVI companies—audit." The email identified nine companies formed in the British Virgin Islands ("BVI") for the Rotenbergs. For each Rotenberg-related company, the email provided the company name, ultimate beneficial owner, a key contact, and company activities as follows: