Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/80

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Companies organized by Omelnitski and his group suggest that Markom may potentially have created numerous companies for Russian oligarchs and close acquaintances of Russian President, Vladimir Putin, who have been previously implicated in questionable undertakings. Furthermore, the ownership of these shell companies appears to be intentionally structured to be opaque in order to hide the identities of true beneficiaries.[1]

Evidence of Ownership by Boris Rotenberg. Finally, evidence also exists that Highland Ventures was owned by Boris Rotenberg. The strongest evidence is the Mossack email chain cited above and released with the Panama Papers, which listed Boris Rotenberg as the UBO of Highland Ventures.[2] According to ICIJ, Highland Ventures was incorporated on January 14, 2010 and registered in the British Virgin Islands using Mossack as an agent.[3] As noted above in the chart, Mossack listed the activities of Highland Ventures as "investments."[4]

Summary of Evidence on Ownership of Highland Ventures Group. The evidence is not conclusive as to whether Arkady, Boris, or Igor Rotenberg, or possibly some combination of the three, qualified as the UBO of Highland Ventures. But the evidence is clear that one or more of the Rotenbergs controlled the company. As a result, the clear implication is that the Rotenbergs directed and funded purchases of high-value art in the United States.

c. Advantage Alliance

In addition to Highland Business and Highland Ventures, the Subcommittee examined the ownership and activities of a third shell company, Advantage Alliance. The Subcommittee became interested in Advantage Alliance due to its role in the purchase of La Poitrine, as explained above.[5]

As mentioned above, evidence suggests that Advantage Alliance had ties to Arkady Rotenberg. A 2017 Barclays internal investigation observed that "Advantage Alliance. . . appears to have received payments from an entity which [the bank] has learned is owned by [Arkady Rotenberg]."[6] Barclays identified the entity that made the payment to Advantage Alliance as Highland Ventures.[7]


  1. Id.
  2. SGA_PSI_00053-82.
  3. Highland Ventures Group Limited, Int'l Consortium of Journalists, https://offshoreleaks.icij.org/nodes/10143427.
  4. SGA_PSI_00053-82.
  5. See infra.
  6. BARC_005572-95.
  7. Id.

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