Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/81

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Barclays also investigated Advantage Alliance's links to the Markom Group and Mr. Omelnitski. A Barclays investigatory memorandum noted that Advantage Alliance's account with the bank was opened in the name of MP Intermediary Services Limited in 2008.[1] The memorandum continued: "The beneficial owner was listed as Alexander Druzhinin, a Russian national. . . . The third party signatories were listed as [Anna] Wilkes, Joseph Amin, and [Mark] Omelnitski. Internet research identified Amin as the Managing Director of Markom Media and Druzhinin as a director of Markom Partners Plc."[2] Ms. Wilkes is identified in another related Barclays investigation as the Finance Director and Managing Director for the Markom Worldwide Corporation.[3] In short, all three account signatories for Advantage Alliance were Markom Group employees. And other evidence previously described established that the Markom Group formed companies and performed related corporate services for the Rotenbergs.

The Barclays investigation of Mr. Omelnitski also noted that when the Advantage Alliance account was opened at the bank, the expected annual turnover for the account was £3 million or about $3,746,670.[4] Despite this expectation, the account was involved in 129 wire transfers from March 2012 to May 2016 totaling $60,972,491.89.[5] The Barclays investigation found that Advantage Alliance engaged in transactions with a wide range of entities, including traders of cocoa products, a security firm, traders of metals, a sourcing company, a brokerage firm, a construction company in Russia, and a supplier of used cooking oil.[6] The Advantage Alliance transactions also included a payment directly to an art dealer for the purchase of La Poitrine, which was sold to Highland Ventures, as further discussed below.[7]

Barclays determined that the wire activity "does not appear to be in line with [Advantage Alliance]'s expected line of business."[8] As such, "the account was closed on October 24, 2016 as Barclays Corporate identified spikes in activity seen during April and May, with large transfers in sent straight out in full as Int[ernational] Payments, which did not match expectations for the nature of the business."[9] Further, Barclays suspected that these funds may be the proceeds of a crime.[10]


  1. BARC_006752-61.
  2. Id.
  3. BARC_006762-65.
  4. BARC_006752-61.
  5. Id.
  6. Id.
  7. Id.
  8. Id.
  9. Id.
  10. BARC_005514-21.

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