Page:2020-07-29 PSI Staff Report - The Art Industry and U.S. Policies that Undermine Sanctions.pdf/89

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According to the Steamort Agreement, Steamort would pay Mr. Baltser $9,500 a month for his services.[1] A review of financial records confirmed that from March 25, 2010 to October 31, 2016, Steamort sent 96 wire transfers to Mr. Baltser's account totaling $907,000.[2] Most of these payments were in increments of $9,500.[3] Almost all of the instructions located in the wire transfer information noted "payment for consulting services in antiques by invoice" followed by a date.[4]

Beginning in 2017, Mr. Baltser began receiving $9,500 payments from two companies other than Steamort, Aester Limited[5] and Sinara Company LP.[6] From March 2, 2017 to April 6, 2018, Aester Limited sent Baltser eight wire transfers in $9,500 increments totaling $76,000.[7] From July 7, 2017 to June 18, 2018, Sinara Company sent Baltser 14 wire transfers in $9,500 increments totaling $133,000.[8] In total, between March 2010 and October 2018, it appears Mr. Baltser


  1. Id.
  2. DBAG0000011; BOFA-40684 (wires from 2010 were not available).
  3. Id.
  4. Id.
  5. Aester Limited was incorporated on December 7, 2016, in England and Wales, with a registered office address of 13 John Princes Street, Second Floor, London, England. See Certificate of Incorporation of a Private Limited Company, Company No. 10514112 (Dec. 7, 2016), https://beta.companieshouse.gov.uk/company/10514112. According to its filing history, on March 16, 2018, ATM Secretaries Limited, the same Secretary of Steamort, was appointed as the Secretary of the company. See Appointment of Corporate Secretary, Company No. 10514112 (Mar. 16, 2018), https://beta.companieshouse.gov.uk/company/10514112. On January 1, 2018, Oleksandr Baksaliar, a Ukrainian national, was listed as a "person with significant control" of the company. See Notice of Individual Person with Significant Control, Company No. 10514112 (Jul. 3, 2018), https://beta.companieshouse.gov.uk/company/10514112. According to the company's confirmation statement filed on December 28, 2018, Aester Limited's principal activity is the "wholesale of furniture, carpets and lighting equipment; wholesale of electronic and telecommunications equipment and parts; wholesale of wood, construction materials, and sanitary equipment; and wholesale of hardware, plumbing and heating equipment and supplies." See Confirmation Statement, Company No. 10514112 (Dec. 28, 2018), https://beta.companieshouse.gov.uk/company/10514112.
  6. Sinara Company LP was registered in the United Kingdom as limited partnership ("LP") on January 16, 2017. Just like Aester Limited, the principal place of business was listed as 13 John Princes Street, 2nd Floor, London, England. See Application for Registration of a Limited Partnership, Company No. LP17803 (Jan. 16, 2017), https://beta.companieshouse.gov.uk/company/LP017803. The general nature of the business was listed as "tourism and ticketing services." See Application for Registration of a Limited Partnership, Company No. LP17803 (Jan. 16, 2017), https://beta.companieshouse.gov.uk/company/LP017803. The partners of Sinara Company LP were listed as Portervale Trading Company and Reox Limited. See Application for Registration of a Limited Partnership, Company No. LP17803 (Jan. 16, 2017), https://beta.companieshouse.gov.uk/company/LP017803. On March 30, 2019, Sinara Company LP was dissolved; Portevale Trading Company signed the dissolution document. See Statement specifying the nature of a change in the limited partnership, Company No. LP17803 (Mar. 30, 2019), https://beta.companieshouse.gov.uk/company/LP017803.
  7. BOFA-40684.
  8. Id.

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