- it does not know, and has no reason to suspect that any buyer is under investigation for, charged with or convicted of money laundering, terrorist activities or other crimes; and
- any shipping of lots on which Baltzer has successfully bid will be done in compliance with all applicable export and import laws.[1]
The new agreement was dated March 19, 2018.[2] The former Global Head of Compliance explained that with the new agreement, the BALTZER account was restricted until the company provided Christie's the required customer documentation.[3] She told the Subcommittee that BALTZER complied with the new requirement and provided the customer information, but continued to pay for purchases from his bank account.[4] Therefore, financially, Christie's was unable to look beyond BALTZER's bank account to determine the source of the funds used to make purchases.[5]
b. Sotheby's Declined to Sign an Agreement with BALTZER LLP, but Continued to Transact with Mr. Baltser
Mr. Baltser also approached Sotheby's to enter into an agreement with BALTZER LLP. While Sotheby's considered the proposal, the auction house ultimately declined. According to a document produced by Sotheby's to the Subcommittee, during the course of the negotiations with Mr. Baltser, the Sotheby's account representative for Mr. Baltser ("Baltser Account Representative"), represented to Sotheby's leadership that Mr. Baltser's clients were Russian oligarchs.[6] She also specifically identified Arkady and Boris Rotenberg as two of Mr. Baltser's clients.[7] But when asked by the Subcommittee to confirm that Arkady and Boris Rotenberg were Mr. Baltser's clients, she said she had fabricated the information to encourage Sotheby's to agree to Mr. Baltser's proposal.[8] The Subcommittee questions her truthfulness in her interview, given the Subcommittee traced funds used to purchase art by Mr. Baltser back to shell companies linked to the Rotenbergs.
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