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The Barclays investigator determined the transfer to Igor Rotenberg was intended to evade U.S. sanctions on Arkady Rotenberg. The investigative report explained:
It should be noted that A[rkady] Rotenberg was listed as an SDN on or about March 20, 2014, over four months before the ownership of Beechwood and Causeway was transferred to his son. Furthermore, such transfer to a non-SDN close relative taking place at the time of sanctions designation does not appear to be a proper transfer to a bona fide purchaser acting at arm's length as defined by the Office of Foreign Asset Control ("OFAC"). Barclays NY believes the transfer of ownership to I[gor] Rotenberg was intended as circumvention of sanctions.[1]
Barclay's investigation concluded with regard to Mr. Omelnitski and the Markom Group:
- ↑ BARC_006804-10.
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