That same day, March 26, 2012, the Business Development Manager sought the Baltser Client Advisor's advice; Mr. Baltser wanted to bid in an upcoming auction in New York.[1] The Business Development Manager emailed:
the "beneficiary" issue is still not resolved. [Mr. Baltser] says that even verbally he cannot confirm anything as he himself doesn't know who the ultimate beneficiaries of Steamort are. He is asking if he can still bid in the sale without this document. What can we do?"[2]
The Baltser Client Advisor responded: "let me check, please. As soon as I have some information], I will let you know."[3] The Baltser Client Advisor responded to the AML Specialist:
Christie's London can accept the verbal confirmation of the beneficiary owner of the company (as an exception). This is a very important client of ours who actively buys in various Gold Sale categories. We worked very hard to encourage this client to participate in the sales and we feel it's a shame to lose him now. The additional documents were requested in February 2012, the client provided them at his earliest convenience. Please advise if I should contact any other colleagues of ours to discuss this urgent matter.[4]
The Baltser Client Advisor confirmed to the Subcommittee that on certain occasions Christie's would accept verbal confirmation of the beneficial owner.[5]
The AML Specialist emailed and requested that she "kindly disclose the beneficial owners, and Legal can conduct the checks."[6] On March 27, 2012, the Business Development Manager informed the Baltser Client Advisor that she would contact Baltser and "try to ask him to at least verbally confirm, the beneficiaries."[7] On March 28, 2012, the Business Development Manager emailed Christie's compliance and stated that "the sole beneficiary of Steamort is Mrs. Luisa Brown."[8] The AML Specialist responded that same day: "Luisa Brown is clear, and the client is fine to bid in the upcoming sale on April 4th."[9] The AML Specialist continued: "Going forward, please note we require documentary confirmation of beneficial ownership in accordance with our Legal requirements
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