Baltzer Limited also listed Markom Directors as its Director and Markom Secretaries Limited as its Secretary.[1]
The following day, Mr. Omelnitski emailed Christie’s in-house counsel in London a copy of BALTZER’s Compliance Procedures Manual.[2] The manual stated:
In addition to our existing money-laundering measures, BALTZER ("Agency") has entered into an agreement with Markom Management Limited ("Markom"), whereby Markom will independently check, verify and handle information about the Agency’s clients.[3]
The manual further stated that BALTZER employees "unclear on the [customer due diligence] steps required when engaging a new client please contact Dr. Mark Omelnitski (the [Money Laundering Reporting Officer]), in the first instance for further advice.[4]
Christie's compliance personnel reviewed the Manual, which identified compliance measures. The Manual indicated that BALTZER had entered into an agreement with Markom for Markom to independently check, verify, and handle information about BALTZER clients.[5] The Manual states that BALTZER clients are required to comply with AML legislation, and identifies obligations arising under the UK's 2007 Money Laundering Regulations.[6] The Manual also included BALTZER's customer due diligence measures, including customer identification procedures for individuals and entities, and provided for enhanced due diligence where the client is a politically exposed person.[7] In addition, Christie's compliance personnel noted that Markom was listed on the HMRC-Her Majesty's Revenue & Customs-Supervised Businesses Register of companies that have registered with HRMC under the UK Money Laundering Regulations.[8]
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