The next day, on February 8, 2012, the Business Development Manager informed the AML Specialist that she spoke to Mr. Baltser and explained to him that there were "some outstanding registration documents" required for Steamort.[1] She told the AML Specialist that Mr. Baltser informed her that "he can get me a copy of the company's registration card and the contract that he has with Steamort ltd. He cannot get us the name of the beneficial owner of the company as this information is unavailable to him."[2] In response, the AML Specialist asked to be put "in touch with the person who he has entered into agreement with."[3] He also reminded the Business Development Manager that "beneficial ownership is required for all business clients, and this information has been outstanding for nearly two years already."[4] The Business Development Manager forwarded the AML Specialist's email to the Baltser Client Advisor requesting advice. The Business Development Manager stated that Mr. Baltser said he would "not bother the directors of the company with any questions and he cannot provide us with the information on who the beneficiaries are. I am stuck."[5]
On February 21, 2012, the AML Specialist asked the Business Development Manager for an update regarding the required Steamort documentation.[6] The following day, February 22, 2012, the Business Development Manager informed the AML Specialist that Mr. Baltser asserted he would provide everything the next week.[7]
A month later, on March 22, 2012, the Business Development Manager emailed the AML Specialist documents regarding Steamort, including the Baltser/Steamort 2008 Services Agreement and the Belize Certificate of Incorporation dated August 28, 2008.[8] The AML Specialist replied stating that the documents confirmed the agreement between Baltser and Steamort, but did not "confirm ownership of the Belize Company."[9] The AML Specialist once again requested that the Business Development Manager confirm the owner of Steamort, stressing that "this inquiry has been open since the fall 2010 sales."[10] On March 26, 2012, the AML Specialist emailed "we will need to restrict the account from future bidding pending confirmation of beneficial ownership."[11]
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