Russian oligarchs Arkady and Boris Rotenberg used a loophole in British law to circumvent the sanctions imposed on them. This is stated in a joint investigation by the BBC and the journalistic organization Finance Uncovered.
The loophole in question is companies that are not legally required to identify their true owners, known as English limited partnerships (ELPs). In 2016–2017 The British government has introduced new transparency rules that require companies to identify their true owners. But ELP did not fall under them.
Since then, ELP has been used to circumvent anti-money laundering laws. Financial crime expert Graham Barrow argues that this opportunity arose due to the fact that partnerships are required to disclose only minimal information about their activities.
The Rotenbergs, investigators found, used ELP to evade U.S. sanctions imposed on them after the annexation of Crimea in 2014. In their case, partnerships were used to purchase millions of dollars worth of art.
One of them is Sinara Company LP, created in January 2017. Between July 2017 and June 2018, it sent 14 transfers totaling $133,000 to an art consultant. According to a 2020 U.S. Senate committee investigation, the consultant "facilitated purchases for the Rothenbergs."