Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/77

 March 5, 2016. On March 5, 2018, all 50,000 shares were transferred to Saffron Nominees Limited.

Barclays also produced documents from Markom that provided additional information on share ownership. These documents included a "Nominee Declaration" dated August 5, 2016 stating that Saffron Nominees Limited held shares of Highland Ventures for Igor Rotenberg. In addition, Barclays produced a Certificate dated November 21, 2016 and filed with the Cyprus Ministry of Energy, Commerce, Industry, and Tourism Department of the Registrar of Companies and Official Receiver Nicosia that listed Saffron Nominees Limited as the owner of shares of Highland Ventures.

Arkady Rotenberg transferred ownership of Milasi Engineering to Igor Rotenberg. Four months after the United States imposed sanctions on Arkady Rotenberg, Markom Group assisted in transferring Arkady Rotenberg's interest in Milasi Engineering to his son Igor Rotenberg at a time before Igor was subject to U.S. sanctions. Markom Group executed this transfer by transferring shares in two holding companies that, together, owned the majority of shares in Milasi Engineering. The transfer of ownership of the two shell companies from Arkady Rotenberg to Igor Rotenberg amounted to also transferring the ownership of Milasi Engineering, since the two shell companies owned the company.

According to documents provided by Mr. Omelnitski to Barclays, prior to July 2014, Milasi Engineering was owned by Beechwood Associates and Kendrick Overseas. Causeway Consulting owned Kendrick Overseas. Arkady Rotenberg owned both Beechwood Associates and Causeway Consulting. Arkady Rotenberg's ownership of Beechwood Associates and Causeway Consulting was also suggested by information in the Panama Papers email chain cited above. In addition, as previously mentioned, the December 31, 2014 Milasi Engineering Report and Financial Statement listed Arkady Rotenberg as the company's ultimate beneficial owner.

Markom Group facilitated the transfer of ownership for Beechwood Associates and Causeway Consulting. Documents provided by Markom Group to Barclays documented the transfer of Beechwood Associates and Causeway Consulting. On July 28, 2014, Arkady Rotenberg transferred his shares in Beechwood Associates