when opening new business accounts, and without it a risk review would have to be conducted."[1]
When questioned by the Subcommittee, the Baltser Client Advisor stated that she had no knowledge of Mrs. Brown and did not know of any connection between Mrs. Brown and Mr. Baltser.[2] Mr. Baltser never provided documentary evidence that Luisa Brown was the beneficial owner of Steamort.[3]
3. Mr. Baltser Established BALTZER Auction Agency and Club in Moscow
The creation of Mr. Baltser's art agency and private club, called BALTZER Auction Agency and Club, added another layer of complexity to the purchase of high-value art by shell companies linked to the Rotenbergs. The creation of BALTZER is further described below. Notably, Mr. Baltser's last name is spelled with an "s" and his art agency with a "z."
In November 2012, prior to forming his agency and club, Mr. Baltser contacted Christie's and Sotheby's to discuss a business proposal with him through his new private club in Moscow.[4] Mr. Baltser sent a letter to Christie's explaining "we have conceived a definitive idea of creating a new company with transparent and clear ideology, which would be able to solve many problems of auction life, guaranteeing to the participants the clean title of transaction and services."[5] Mr. Baltser indicated his new company's club would be used by "a whole class of contemporaneous collectors" that he had created and who were "the leading Moscow and Russian collectors—the active participants of auction biddings at many world marketplaces."[6]
a. Christie's Partnered with Mr. Baltser
Beginning in late 2012, Christie's and Mr. Baltser began discussing a potential partnership. On December 17, 2012, the Managing Director of Growth Markets for Christie's in London ("Managing Director"), sent an email to Mr. Baltser to inform him that Christie's has "all of the key people internally at Christi[e]'s together to discuss your interesting proposal. We are consolidating a list of questions which we will have with you by the close of business tomorrow evening and looking forward to continuing discussions with you."[7] The following
90
