Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/78

 Ltd and Causeway Consulting Ltd to Highland Ventures. To document the transfers, Joseph Amin, Deputy Chairman of the Markom Group, sent letters on Markom Group letterhead to Arkady Rotenberg regarding both companies stating: "following the sale of this company to the third party we hereby inform you of the termination of our services to you in regard to the above mentioned company." The Markom Group asserted the transfer of ownership of these two companies effectively transferred ownership of Milasi Engineering to Igor Rotenberg. The Markom Group provided to Barclays a Deed of Trust dated February 18, 2010, making Markom Nominees the trustee of 50,000 shares of Highland Ventures on behalf of Igor Rotenberg.

The Barclays investigator requested information from Markom Group on the consideration Highland Ventures paid for the shares in Beechwood Associates and Causeway Consulting "to ensure that the companies were not merely being transferred by Arkady to his son Igor." Markom Group responded to the request as follows:

"Both Beechwood Associates and Causeway Consulting had been advanced loans by Highland Ventures Group Ltd. As neither Beechwood nor Causeway were able to repay these loans, the loan liability was converted into Share Purchase Agreements ('SPAS') through which Highland Ventures Group Ltd became the new shareholder of the companies. The overall consideration price for the shares of Beechwood that was paid amounts to 6 billion Rubles [approximately $99,889,020.00]; and the consideration price paid for Causeway was 3 billion Rubles [approximately $49,950,000.00]."

The Markom Group provided Barclays with the following chart to explain the ownership structure: