project is on hold now. Gregory is very much concerned that he is missing all major auctions in May, June and July (and is under impression we [are] no longer interested in cooperation).[1]
On March 22, 2013, the Managing Director replied that he needed "to get [the President of Christie's Europe] to focus on this and will try and do so today and send an appropriate message to Mr. Baltser."[2] On March 27, 2013, the Baltser Client Advisor emailed the President of Christie's Europe requesting his "thoughts on Gregory Baltser's project discussed yesterday and if we could proceed with it on the IT front."[3] On April 12, 2013, the President of Christie's Europe approved moving forward with the project with Baltser "as long as there is no corporate risk."[4]
On April 24, 2013, Christie's representatives met with Mr. Baltser in Moscow to discuss the partnership between Mr. Baltser's art agency and Christie's.[5] Present at the meeting were Mr. Baltser, the Managing Director, the Business Development Manager, and the Baltser Client Advisor.[6] The meeting resulted in a list of action items to move the partnership forward.[7]
i. Mr. Omelnitski Served as the Money Laundering Reporting Officer for BALTZER LLP
The action items noted that Mr. Baltser "further explained that their Trustee in London was familiar with the [KYC] process and they have a system approved by the Russian government."[8] On June 5, 2013, Mr. Omelnitski emailed the Managing Director, stating that Mr. Baltser asked him "to contact [you] in regards to arranging a meeting for purposes of identifying of required [AML/KYC] compliance procedures and policies."[9]
On August 12, 2013, Mr. Omelnitski emailed corporate documents regarding the "new Baltser structure" to Christie's Senior Compliance Counsel ("Compliance Counsel"), including incorporation records pertaining to the newly created Baltzer entities—Baltzer Limited (Cyprus) and BALTZER LLP.[10] The Shareholders Certificate for Baltzer Limited listed Markom Nominees LTD as shareholder.[11]
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