Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/73

 Markom Nominees Limited is listed as a shareholder of Highland Business beginning on January 14, 2010. Mossack is listed as the company's agent.

The Panama Papers email chain described above listed Igor Rotenberg as the ultimate beneficial owner for Highland Business. But other evidence suggests that Highland Business Group received its funding from entities associated with Arkady Rotenberg. For example, $47,000 was transferred from Advantage Alliance Limited ("Advantage Alliance") on March 27, 2012 with the payment details: "as per agency agreement." As explained below, a Barclays' internal investigation linked Advantage Alliance to Arkady Rotenberg.

b. Highland Ventures Group Limited

The Subcommittee traced funds for certain art purchases to Highland Ventures Group Limited ("Highland Ventures") following the imposition of U.S. sanctions in March 2014 on Arkady and Boris Rotenberg. Conflicting evidence collected by the Subcommittee regarding the ownership of Highland Ventures places Arkady, Boris, and Igor Rotenberg as the owners of the company at various points in time. As explained below, the strongest evidence suggests that Arkady Rotenberg funded the shell company, which would make him the UBO.

Evidence of Ownership by Arkady Rotenberg. Wire transfers in U.S. dollars sent by Milasi Engineering Limited ("Milasi Engineering"), a company owned by Arkady Rotenberg to Highland Ventures suggest that the true UBO of Highland Ventures was Arkady Rotenberg.

Arkady Rotenberg owned Milasi Engineering. Documents produced to the Subcommittee as part of an investigation conducted by Barclays included a December 31, 2014 Milasi Engineering Report and Financial Statements. That document listed "Arkadiy Rotenberg" as the company's UBO. That same document stated that Milasi Engineering was incorporated in Cyprus on September 6, 2007 and "the principal activities of the company are the holding of investments and loan financing."

Milasi Engineering funded Highland Ventures. Wire transfers produced to the Subcommittee show that Milasi Engineering transferred millions of U.S. dollars