Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/106

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  1. He is well known to the dealer community for the last 15 years. We assume we are happy that he transacts as usual, if we decide not to recognize his new plans.
  2. He can manipulate a market by a ring. There is no evidence at all to support this. Anyway this is not in his interest as the more clients he gets to bid the more fees he can charge.
  3. His business becomes too powerful and he dictates terms to us. We don't think that will happen as we do not see this business growing into 100s of clients. Exclusivity is important to Russians. Also there are too many factions between the powerful elite who will always use different agents and dealers. There are many more powerful buyers in the market and full [buyer's premium] is paid by all.[1]

The email to the Managing Director continued:

Whilst we must be fully compliant it does seem duplicitous that we allow him to bid today but have worries when he explains his ambitions. Furthermore we allow other European and US agents that bid on behalf of clients and we do not demand to know who their clients are.[2]

The email then asked the question: "Should we be partners?"[3] And concluded, "In our opinion, no. If Baltser has more clients bidding in our sales we benefit anyway. If his business succeeds and we think this is a winning formula we should then consider changing our office model."[4]

As with Christie's, Mr. Omelnitski provided documentation of anti-money laundering and client due diligence policies and procedures to Sotheby's on behalf of Mr. Baltser, including a 50-page BALTZER LLP compliance procedures manual and customer due diligence measures, as well as BALTZER LLP incorporation documents.[5] He also advocated for Mr. Baltser saying "Gregory is really anxious to commence co-operation with Sotheby's" on October 11, 2013.[6]The Baltser Account Representative told the Subcommittee she understood that Mr. Omelnitski was Mr. Baltser's representative in the United Kingdom and that his role appeared mainly to involve helping Mr. Baltser set up BALTZER LLP.[7]


  1. Id.
  2. Id.
  3. Id.
  4. Id.
  5. SOT-005232-82.
  6. SOT-004597-99.
  7. Subcommittee interview of Sotheby's Baltser Account Representative (Jun. 27, 2019).

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