Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/72

 created multiple shell companies for [the] majority shareholders of Idealbank, which was investigated due to its possible connections to terrorist financing and money laundering concerns and subsequently was stripped of its banking license in Russia.

The same Barclays memorandum noted, "[T]he ownership of these shell companies appears to be intentionally structured to be opaque in order to hide the identity of the true beneficiaries."

Barclays closed all Markom Group and Gregory Baltser-related accounts. Following the investigation, in August 2017, Barclays worked to close all "198 accounts under the Markom relationship," of which 59 were U.S. dollar accounts. Barclays also closed all accounts related to Mr. Baltser. Documents provided to the Subcommittee indicate that in 2018 Baltzer Limited subsequently began paying for art from an account at Ameriabank in Yerevan, Armenia. In 2018, the U.S. State Department listed Armenia as a "major money laundering jurisdiction" and noted that "money laundering crimes in Armenia [would] likely continue to go unreported and undetected."

2. Rotenberg-Linked Shell Companies were Used to Purchase Art

The Subcommittee identified three shell companies connected to the Rotenbergs and used in the purchase of art both before and after the imposition of U.S. sanctions: (1) Highland Business Group Limited; (2) Highland Ventures Group Limited; and (3) Advantage Alliance. The known ties to the Rotenbergs are explained below.

a. Highland Business Group Limited

The Subcommittee traced certain art purchases to Highland Business Group Limited ("Highland Business") prior to the imposition of U.S. sanctions on Arkady and Boris Rotenberg in March 2014. According to ICIJ, Highland Business was incorporated on January 14, 2010 and registered in the British Virgin Islands.