Sotheby's declined to enter a similar partnership with Mr. Baltser but continued to do business with him -- even after a Sotheby's employee told her managers in 2012 that Mr. Baltser was an adviser to the Rotenbergs, the report said. The employee later told investigators she had lied to her managers and didn't actually know Mr. Baltser bid for the brothers. Sotheby's said in the report she merely spotted the Rotenbergs in a article about wealthy Russians and pitched them as potential clients, pre-sanctions.

In January, Mr. Baltser wrote a column for Forbes Russia where he said the art market needed to be prepared to divulge more ownership details in art deals moving forward. "I would call these changes revolutionary," he wrote. "And although the movement towards transparency is compulsory and not welcomed by everyone, these innovations are undoubtedly a healthy and positive trend: the conservative art industry lacked an openness towards which the whole world is gradually moving."

Write to Kelly Crow at kelly.crow@wsj.com