day, Mr. Baltser emailed the Managing Director that he was glad "we are moving forward with the proposal and I expect way more activity going with the auctions as soon as I get this new structure set. . . . and I will be happy to answer and clarify all the questions in a timely manner."[1]
On December 18, 2012, the Managing Director provided Mr. Baltser with a list of questions raised by various members of the Christie's team regarding his proposal, including:
- Do you intend to bid on behalf of [the art club] or on behalf of the third party?
- Will you be able to take on responsibility to obtain all necessary KYC/AML (Know your client and Anti money laundering) checks required? What structures are in place to ensure these protocols are met?
- Will we know the names of the clients or will all details be held by you and the company?[2]
Beginning in early 2013, representatives from Christie's began traveling to Moscow to meet with Baltser and his team regarding the proposal.[3] On January 22, 2013, Mr. Baltser sent the Baltser Client Advisor a reply to the Managing Director's questions, stating:
We are currently in the process of reviewing Russian laws and related legislation pertaining to KYC/AML. One of the key components of the KYC/AML process implies checking the identity of every client and collecting Personally Identifiable Information (PII). According to Russian legislation as well as the Confidentiality Agreement between Company and our clients, [Mr. Baltser's agency] is obligated not to disclose [personally identifiable information] data to any third parties without the Client's consent, except as may be required by law or court order. Considering this, we are ready to accept responsibility for such processes as KYC (know your customer) and AML (anti money laundering).[4]
On March 21, 2013, the Baltser Client Advisor emailed the Managing Director to inform him that she is "in regular contact with Mr. Gregory Baltser regarding various auctions and client purchases" and explained that he:
keeps on asking if we are ready to proceed with our IT advice and further discussions of his proposed project. Unfortunately, Gregory cannot proceed with ordering any technical equipment and his whole
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