Mr. Omelnitski provided the certification to the Compliance Counsel on December 2, 2014 titled, "AML Report on behalf of 'Baltzer' for period October 2013 through November 2014."[1] The document stated:
I can confirm that our investigation did not reveal any irregularities, which were concerning. I can further confirm that despite BALTZER having a significant number of Russian clients there were no transactions, which fall under recent sanctions against Russia.[2]
The former Global Head of Compliance told the Subcommittee this language satisfied the certification requirement in the February 14, 2014 Letter Agreement.[3]
2015. A year later, on December 3, 2015, the Compliance Counsel emailed Mr. Omelnitski asking, "could you please let me have a compliance report for this year?"[4] Mr. Omelnitski did not provide the requested compliance report.[5]
2016. The Compliance Counsel emailed Mr. Omelnitski on June 7, 2016 and again asked, "would you please be able to send me a compliance certification again similar to the report you so kindly provided at the end of 2014?"[6] Mr. Omelnitski did not provide the requested report.[7] On June 28, 2016, the Compliance Counsel again requested that Mr. Omelnitski "confirm when we can expect to receive your compliance certification?"[8] Mr. Omelnitski failed to provide the requested compliance report.[9]
2017. On July 13, 2017, the Compliance Counsel emailed Mr. Omelnitski stating, "we will need the compliance certificate from you as per our agreement."[10] On October 9, 2017, Mr. Omelnitski emailed information regarding BALTZER's purchases.[11] Mr. Omelnitski's email stated that for "transactions September 2016-September 2017," Baltzer's agency "had the turnover of £3,269,457.30, Euro 5,775,449.40 and USD 1,402,661.60."[12] The email broke down those amounts between auction houses, clients, and suppliers.[13] The email did not provide any certifications regarding compliance with AML policies as required by the Letter
- ↑ Christies-PSI-00035361-62.
- ↑ Id.
- ↑ Subcommittee interview of Christie's former Global Head of Compliance (Jul. 15, 2019).
- ↑ Christies-PSI-00098858.
- ↑ Subcommittee interview of Christie's former Global Head of Compliance (Jul. 15, 2019).
- ↑ Christies-PSI-00098961.
- ↑ Subcommittee interview of Christie's former Global Head of Compliance (Jul. 15, 2019).
- ↑ Christies-PSI-00098976.
- ↑ Subcommittee interview of Christie's former Global Head of Compliance (Jul. 15, 2019).
- ↑ Christies-PSI-00093620-23.
- ↑ Christies-PSI-00093885-87.
- ↑ Id.
- ↑ Id.
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