Can I use an estimate of the bank balance on the FBAR 114?

My client is a US citizen living in the Middle East and keeps his money in Middle Eastern banks.  He moved during the year from one country to another and claims he did not get his bank statements prior to the move.  He closed the account and now claims he can't access the bank statements.  He says he has tried to call the bank over and over but they do not EVER answer the phone.  I have given him several suggestions and offered to step in and help to no avail.  It does not appear that he has done anything but call a phone number that does not answer.  He did try to email the bank, but the response only says to call the bank.

At this point I am trying to make him sweat because he knows he needs the bank statements.  He is going into a panic and wants to file the returns without them.  He went so far as to say that I should write the FinCen a letter!  I told him to write the bank a letter.

I don't know if he is really that naive or if there is something else, but it makes me very suspicious.

I can use an estimate based on 2016 and I have his pay stubs for 2017 so I can get close I think.

Does anyone have any ideas of how to handle this? 

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