Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/105

However, the Baltser Account Representative stated in her Subcommittee interview that Mr. Baltser never represented to her that Arkady and Boris Rotenberg were his clients.^[1] She stated she fabricated the fact the Rotenbergs were clients of Mr. Baltser to convince her employer, Sotheby's, there was "significant business potential" in the agreement with Mr. Baltser.^[2] She stated she located the two Rotenbergs by googling Russians on the Forbes list.^[3] The biographies attached to her email listed Arkady Rotenberg as number 1,153 on the Forbes list and number 30 in Russia.^[4] The biography for Boris Rotenberg listed him as number 1,031 on the billionaires list and number 69 in Russia.^[5] The Subcommittee questions the truthfulness of Baltser Account Representative's answer given that funds used by Mr. Baltser to purchase art were traced back to shell companies linked to the Rotenbergs.

In order to facilitate a decision on Mr. Baltser's proposal, the Baltser Account Representative and the Chairman of Sotheby's Russia drafted a list of pros and cons.^[6] Once they both agreed on the list, they sent the list to the then Managing Director for Sotheby's Europe ("Managing Director") on October 15, 2013.^[7] The list included the following positive points they associated with the proposed business arrangement with Mr. Baltser:

1. Baltser has a client base that wants to buy in our sales and have already been buying using Baltser's services. We encourage his bids and he pays on time.
2. He declared his plans willingly and honestly to us. He is regulated by the Russian authorities and before accepting to deal with any of his potential clients he has to go through KYC and do all due diligence.
3. His logistics operation, to make buying in auction houses easy and fun, appeals to a number of wealthy Russians who trust him. Among his clients are Forbes list businessmen.
4. On several occasions the identity of his clients has been revealed to us and we set up personal accounts for these clients. Some have already started transacting with us directly.^[8]

The list also included "concerns:"

1. We do not always know who his clients are. We do however know Baltser well and we have transacted with him for a number of years.

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1. Subcommittee interview of Sotheby's Baltser Account Representative (Jun. 27, 2019).
2. Id.
3. Id.
4. SOT-018689-93.
5. Id.
6. SOT-051481-82.
7. SOT-018663-64.
8. Id.

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