Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/71

 {| class=wikitable ! Company ! Ultimate Beneficial Owner ("UBO") ! Contact ! Activities
 * Beechwood Associates Inc.
 * Arkady Rotenberg
 * Dmitry Protsenko
 * Investments
 * Breckenridge Global Management Limited
 * Arkady Romanovich Rotenberg
 * Dmitry Protsenko
 * Investments
 * Causeway Consulting Limited
 * Arkady Rotenberg
 * Dmitry Protsenko
 * Investments
 * Culloden Properties
 * Boris Rotenberg
 * None
 * Investments
 * Highland Business Group Limited
 * Igor Rotenberg
 * Dmitry Protsenko
 * Investments
 * Highland Ventures Group Limited
 * Boris Rotenberg
 * Dmitry Protsenko
 * Investments
 * Kendrick Overseas Ltd.
 * Rotenberg
 * Dmitry Protsenko
 * Holding
 * Stormont Management Limited
 * Igor Rotenberg
 * Dmitry Protsenko
 * Investments
 * Stormont Systems Limited
 * Igor Rotenberg
 * Dmitry Protsenko
 * Investments
 * }
 * Igor Rotenberg
 * Dmitry Protsenko
 * Investments
 * Stormont Systems Limited
 * Igor Rotenberg
 * Dmitry Protsenko
 * Investments
 * }
 * }

The email chain provides evidence that Mr. Omelnitski, through the Markom Group, had a business relationship with the Rotenbergs. It also provides evidence that Arkady, Boris, and Igor Rotenberg established at least eight BVI companies for use in activities related to "investments" and one holding company. Two of these companies, Highland Business Group Limited and Highland Ventures Group Limited, played key roles in their art investments as described further below. In addition to the Panama Papers, evidence of links among the Rotenbergs, Mr. Omelnitski, the Markom Group, and the listed shell companies were the subject of an internal investigation performed by Barclays Bank ("Barclays") and provided to the Subcommittee. Following the release of the Panama Papers in 2016, Barclays reviewed the companies formed by Mr. Omelnitski and the Markom Group. A Barclays internal investigatory memorandum concluded:

Omelnitski and his company, Markom Group, created shell companies for sanctioned individual [Arkady] Rotenberg, a Russian oligarch, who is a close friend of the President of the Russian Federation, Vladimir Putin. Omelnitski is listed as a beneficial owner for the three companies owned by [Arkady] Rotenberg. Omelnitski and his company are nominee directors of multiple unidentifiable shell companies formed in Panama by Mossack Fonseca and the majority of these shell companies are owned by Russian individuals. Markom Group had