behalf of someone else.[1] At that point the agent will provide the details of the end purchaser so that Phillips can issue an invoice in the name of the purchaser.[2] According to him this happens for several reasons, including: (1) the agent does not want to pay for the purchased item himself; and (2) agents want any legal liability for the purchase to transfer to the purchaser.[3] Phillips then conducts "know your customer" checks on the actual purchaser.[4]
He acknowledged that there could be circumstances in which an agent may have a principal that pays the agent directly.[5] This would result in what he termed a "back-to-back transaction" whereby the invoice would remain in the name of the agent, and in those instances the auction house would not be aware of the second transaction.[6] He stated that Phillips' preference is to have the person in the room bidding be the person invoiced and responsible for that sale, but sometimes it is not that simple.[7]
2. Mr. Baltser Purchased Art as an Agent for Steamort
Mr. Baltser used a shell company to purchase art, which adds another layer of complexity to the connections between the Rotenbergs and the high-value art market. Prior to the imposition of U.S. sanctions against Arkady and Boris Rotenberg in March 2014, the majority of purchases Mr. Baltser made that the Subcommittee linked to the Rotenbergs were in the name of Steamort Limited ("Steamort"). Steamort was incorporated in Belize on August 28, 2008.[8] Steamort's principal place of business, however, was listed as 10 Great Russell Street; London, England.[9] According to the company's Certificate of Incumbency dated September 12, 2012, Steamort's only director and shareholder is Jason Hughes, a British national residing in Cyprus.[10] The Certificate of Incumbency states that Mr. Hughes holds the company's 50,000 shares.[11] That same Certificate lists ATM Secretaries Limited as the Secretary of Steamort.[12] Steamort has maintained a bank account at Tallinn Business Bank in Estonia since at least April 30, 2009.[13]
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