that his clients were compliant.[1] She recalled that Mr. Baltser provided additional company and compliance documents to address Sotheby's KYC concerns. She explained that dealers and art galleries never disclose who their clients are. However, she noted that any gallery owner was responsible for running its own client due diligence.[2] She stated that Sotheby's did due diligence on Mr. Baltser as the client, but Mr. Baltser would perform the due diligence on his own clients.[3]
In summer 2013, Mr. Baltser continued to push regarding a partnership between himself and Sotheby's.[4] Through the Baltser Account Representative, Mr. Baltser requested a meeting to "address all the questions and issues we have with" his proposal.[5] In the same June 6, 2013 email, the Baltser Account Representative noted that "this week Gregory has set up a record for a Russian painting at auction buying Nichols Roerich's canvas at Bonhams for [£7.88 million]," referring to Mr. Baltser's purchase of the Madonna Laboris.[6]
iii. The Baltser Account Representative Claims Arkady and Boris Rotenberg were Mr. Baltser's Clients before they were Sanctioned
As part of her continued advocacy on behalf of Mr. Baltser, and his business proposal to Sotheby's, the Baltser Account Representative created a document in advance of a meeting on October 9, 2013 that showed Mr. Baltser's clients included, Arkady and Boris Rotenberg.[7] The Baltser Account Representative sent an email to her assistant that attached Forbes biographies of the men.[8] The Deputy Chairman of Sotheby's Europe and Chairman of Sotheby's Russia ("Chairman of Sotheby's Russia") told the Subcommittee during an interview that when he saw the list that included Arkady and Boris Rotenberg, he thought, "It looked quite impressive to me to have [] oligarchs on the list."[9] He confirmed that he believed the compliance department and the managing director of Sotheby's would have seen the client list at the time, which was before sanctions were imposed on Arkady and Boris Rotenberg.[10]
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