Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/76

 explained below, the Subcommittee traced that $7.5 million payment to another company owned by Arkady Rotenberg, Senton Holdings Ltd.

Barclays also linked Advantage Alliance to Highland Ventures. An internal Barclays' investigation linked Highland Ventures to Advantage Alliance through two wire transfers to Highland Ventures from Advantage Alliance between November 2015 and March 2016, which totaled $381,347.70. Details provided about the payments indicated: "as per agency agreement."

Together, the Milasi Engineering transfers, the UK government agency conclusion, and the facts surrounding the purchase of La Poitrine suggest Arkady Rotenberg is the UBO of Highland Ventures.

Evidence of Ownership by Igor Rotenberg. There is also some evidence that the true UBO of Highland Ventures was Arkady's son, Igor Rotenberg. First, a Barclays investigator summarized this finding in an April 6, 2017 email stating:

"Markom Management Ltd have confirmed that Highland Ventures Group Ltd was never owned by Boris Rotenberg. It has in fact always been owned by Igor Rotenberg since it was incorporated on [February 18, 2010] Igor is not subject to the current US sanctions, however, as you are already aware he is the son of Arkady Rotenberg who is a sanctioned individual."

The April 2017 email also pointed to evidence provided by Markom Management that Igor Rotenberg owned Highland Ventures. That evidence included a Trust Deed between Igor Rotenberg and Markom Nominees Ltd dated February 18, 2010 stating that Igor Rotenberg had granted 50,000 shares of Highland Ventures to Markom Nominees Ltd as trustee.

Saffron Nominees Limited held Highland Ventures. In addition, Markom Management provided documents to Barclays that indicated that Igor Rotenberg owned Highland Ventures through another company named "Saffron Nominees Limited." A document titled "Register of Shareholders" for Highland Ventures stated that Markom Nominees Ltd held 50,000 shares from February 18, 2010 to