received $1,116,000 in fees for his consulting services under the Steamort Agreement.[1]
Christie's questioned Steamort's ownership. Prior to U.S. sanctions in March 2014, Mr. Baltser purchased art from the auction houses in Steamort's name. The Christie's client representative for Mr. Baltser ("Baltser Client Advisor") told the Subcommittee that Mr. Baltser introduced himself as someone who purchased art on behalf of other people.[2] The Baltser Client Advisor explained, "one thing's for sure, he's not buying it for himself."[3]
Christie's requested information on Steamort's UBO from Mr. Baltser. On November 29, 2010, following the registration of Steamort's account, Christie's internally requested information regarding the "confirmation of the directors of the company" and "confirmation of who is the ultimate beneficial owner of the company."[4] The request went unanswered until February 7, 2012.[5]
On February 7, 2012, Christie's compliance department emailed the Business Development Manager Business Development Manager about the documentation requested in 2010 for Steamort's company directors and the ultimate beneficial owner.[6] The email noted that Mr. Baltser was listed as Steamort's owner in the client profile, but additional documentation was required.[7] The Business Development Manager responded that she was unable to reach Mr. Baltser due to the time difference between London and Moscow, explaining:
I have tried to get in touch with the client, but he is probably sleeping as he is supposed to bid very early in the morning our time. Steamort/Grigoriy [sic] Baltser have been regular client of Christies. Just today he participated in a sale in London and is bidding tomorrow as well. He is a very respected businessman and I personally know [him] very well. Is it possible for me to get this documentation to you after the sale. He is bidding on 19 lots![8]
An AML Specialist also from Christie's compliance department responded, "if you could follow up after the sale it would be greatly appreciated."[9]
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