Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/75

 individuals or specifically designated nationals blocked from doing business with U.S. persons.

The multi-million dollar transfers between Milasi Engineering and Highland Ventures are strong evidence of the shell company's link to Arkady Rotenberg.

A United Kingdom government agency determined Arkady Rotenberg owned Highland Ventures. In addition to the fund transfers described above, a 2018 letter by Barclays indicates that a UK government agency concluded that Highland Ventures was owned by Arkady Rotenberg. On May 18, 2018, the Head of Financial Crime Policy at Barclays Bank sent a letter to Alexandre Manfull, the Assistant Director of Sanctions Compliance & Evaluation at OFAC, stating "in August 2017, Barclays was contacted by [a UK government agency] who provided Barclays with a list of entities that [it] believed to be owned or controlled by Arkady Rotenberg, including Highland Ventures."

A Societe Generale investigation linked Highland Ventures to Arkady Rotenberg. An investigation by Societe Generale determined that an account at another financial institution owned by Highland Ventures was "utilized as a pass-through account for layering activities to channel and conceal a flow of funds" Further, Societe Generale "was unable to rule out that the processed funds did not originate from a sanctioned individual, the father of Igor Rotenberg," Arkady Rotenberg.

An art purchase through an independent dealer linked Highland Ventures to Arkady Rotenberg. An invoice and transfer of funds associated with a private art purchase investigated by the Subcommittee provided another piece of evidence suggesting Arkady Rotenberg was the UBO of Highland Ventures. As further explained below, the private sale of a famous painting by René Magritte called La Poitrine listed Highland Ventures on the invoice as the buyer. The Markom Group assisted with the purchase of La Poitrine; Anna Wilkes (Finance Director and Managing Director for the Markom Worldwide Group) signed the invoice as the Director of Highland Ventures. The invoice listed Advantage Alliance as the entity that provided payment for La Poitrine, which totaled $7.5 million. As