Case File
efta-01284148DOJ Data Set 10OtherEFTA01284148
Date
Unknown
Source
DOJ Data Set 10
Reference
efta-01284148
Pages
10
Persons
0
Integrity
Extracted Text (OCR)
EFTA DisclosureText extracted via OCR from the original document. May contain errors from the scanning process.
KYC Print
Page I of 10
DB PWM GLOBAL KYC/NCA: PART A
KYC Case * : 01790724
One sheet must be established per relationshi • list all accounts included in the relationshi
1. Relationship Details
Relabonship Name:
SOUTHERN FINANCIAL FtELATIONSHIP.00000.483293
Booking Center:
New York
Relationship Manager:
stewart oldfield
III New FUN Relationship
74 Existing PWM Relationship
Relationship to WM:
If existing, please indicate since when the relationship exists, provide reason for new profile and attach old profile. • "This
KYC is a periodic review for high risk renxdiation"'
Original KYC1161376
Client Referral
O RM Prospect
O Interrnediary/FIM
•
Other Source (Cw, etc.)
How Was the Client(s)
Introduced' How long has the
RM personally known the
client'
Please mime defogs (e.g. name
ral source,
is Rat personally has known client, etc.): Stewart Oldfield
and Cynthia Rodriguez contacted
and
/2017 to confirm If there are any material changes
to their Joint accoun and source of wealth. The
imed that
is now the sole provider of their household. She
provided recent paychecks to confirm this.
relies on
Income to support her Ifestyk.
Does Deutsche Bank pay a
retrocession or similar
O yes
10 No
compensation to a third party
for the introduction of this
feletimship7
Of Yes, describe).
List as exisbng and new account Involved in this relationship
Legal Entity
Account(s)
Account Name / Number
Opening Date (intended/actual)
1
0
Deposit
12/16/2013
Who is the primary contact
person for the RM? (Note:
This person needs to have
signatory rights and/or
Information right for the
account.):
Preferred method of contact
(mdicate phone no., fax no.,
e-mall address, etc.):
Status : 6. Approved
SDNY_GM_00040061
hups://dbforcepb.my.salesforCCINBIDaiLIJIAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0002885
EFTA_00150670
EFTA01284148
KYC Print
Page 2 of 10
One sheet must be established for each account to be opened
2. Account Ownership Summary
Account Name:
Deposit
Acct. Number ft avatiadal.
Account Manager:
stewart oldfleld
What is the purpose of the account (e.g. portfolio ma
ent_,__advisonr account custody services, long-term investment, PaYment/aPerne
account)' Checking account fa the daily use of
and M
Indicate from where the assets are expected to entre'
g
08 Group: Same Booking Center (indicate account number):
El 08 Group: Other Booking Center (indicate 08 location and account details):
O Other Institution - (Indicate name 8 location):
•
Physical Deposes (specify cash, securities, cheques, ...):
What is the expected sloe and frequency of regular inflows and outflows for the account (Indicate estimated number and volume per month)': 0-4 :Awes and
outflows per month ranging from $100 to $1500
What is the expected volume of assets and currency for the account approx. 90 days
after opening'
1 10000
I Currency
I USD
What is the expected volume of assets and currency for the account approx. one year
after opening'
14379.40
I Currency
I USD
Doeshvil the client have Assets Under Management (AuM) within D8 under Eur. 3M'
Dyes 2 No
Please Nat all parties related to the account.
For each party:
• Check d a source of wealth description is required for the party.
• Check the appropriate box to describe the relationship of the party to this account (> lean be selected).
• If none of the check boxes apply, describe the parties relation to the account in the 'Other' column.
• Always describe the relationship between the parties in the last column.
• Please drill down to the uttlmate/underlying Beneficial Ovmer(s).
.ecial
Zottyof
)escripticri
Source
of Weath
required
roes
fated
this
count
AccounWIC
Holder OwnerTrust
Setikr d
/
Founder of
Foundation
Jitimate
Beneficialor
Owner
SignatorrtimitedIRnancial
Full
POA
POA
Intermediary
(FIM)
Significant
Shareholdergepresentattre
„.> =25%)
ilon-PIC
entity
indicate
Dwnership
it)
_egal
Grantor/Settloreounding
Donor
Other
(please
lescribe
other roles
end/or
ndlcate
relationship
Sebum
arbes)
1
O
O
2
El
•
TA
71
O
O
O
O
•
2
O
0
TA
O
O
D
O
DD
O
•
O
SDNY_GM_00040062
https://dbforcepb.my.salesforCLINErilDEgrialliAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0002886
EFTA_00150671
EFTA01284149
KYC Print
Page 3 of 10
One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa
3A. Individual Details (for all parties)
Indhicluars Name:
- 00000489505
Date of Birth:
Country of Residence:
USA
Country of Citizenship:
I.I
Address of primary residence:
Has client resided outside of
his/her country of nabonalty
Ice 5 years Of morel
O yes Pi No
Profession/Occupatton:
homemaker
Tax ID / 55N:
Current Employer
PositonMUe/Rank:
Address of employer:
Does the person work as 141O:r executive of a DB-recognued regulated entity in the financial
Mosby' or an entity listed on
DO-recognised exchange' (Not applicable for operating
entitles
Oyes ®No
Is the individual a Politically Exposed Person (PEP)1(d Vet *suite)
OYU
®N0
TO the best of your knowledge,
Family or Friendship, desalt.)
Is the Individual related to an employee of the DB grOup?(f
OFamily
OFriendshlp
rd None
To the best of your knowledge, is the individual party to a non-banking rdabcriship with
Deutsche Bank (e.g., external legal counsel, client referral source, supplier Cl goods or
servxes),(6 Yes,descabe)
ElYes
Ft No
If appkcable, indicate valid, bank officers have met the
person.
Indicate Mere and Mien the client meeting(s took place:
Bank Officer tia imp)
Bank Office:
Client Private
Dcmkile:
Client Place of
/Business:
Other Location (specify):
Paul Morris
D
12e3.2013
•
74
LI
O
•
r,.
O
n
• Wealth Details for this individual are not filled in, because they are the same as for the folkymng person:
3B. Wealth Details (Only for parties requinng source of wealth description as indicated in Section 2)
Nature of the Individuals Business:
homemaker
Pnmary Country of source or wealth/source of Funds,
Primary industry of source of Wealth/Source of Funds'
Summarize Source of Wealth:
1
DOther:
E Business Owner III Salary/Earnings El Investment El Inhentance/Grfts
Further Describe Source of Wealth /Detail the history d wealth for each of the sources: (e.g. For trusts, how did settlor accumulate wealth' For inheritance,
how did family accumulate wealth'For business owners, Nov
'
iness, how many employees, level of profitability' Indicate type of business,
countries of major activities, important business partners.)
used to work for NES, LLC (existing DB client and previously kyc approved) which is
the LISS4S is used to run Jeffrey Epstdris New York Ctty home. The legal addr
f
• n
but the home is Kalif"
East 71 St New York
NY.
no longer manages the NYC home and solely relies on the Income o
She has relied on
income for the past 3
years
Estimated Annual Incorne(S):
Estimated amount of investable assets(S):
<31 W
Estimated Net Worth(S):
<S1 MM
Amount of assets planned to invest with PWIN(S):
20,000.00
Cther Knows Financial Institutions:
Institut:km:
I Wriorgan
I
I Utak
lEst Assets Under Mgt
160,003.00
SDNY_GM_00040063
t ps://dbforcepb.my.salesforcalINEJIDEATML000000D9DiSice... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0002887
EFTA_00150672
EFTA01284150
KYC Print
Page 4 of 10
Institution:
Est Assets Linda Mgt:
Insbtubcei:
Est Assets Linder Mgt:
Please indkat the family stualicc of the individual (marital status, other family members, etc )
1=I=1
SONY_GM_00040064
https://dbforeepb.my.salesforeCaNErilDaatiAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0002888
EFTA_00 150673
EFTA01284151
KYC Print
Page 5 of 10
One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa
3L Individual Details (for all parbes)
Individual% Name:
- 00000489504
Date of Birth:
Country of Residence:
USA
Country of Citizenship:
Address of primary residence:
Has client resided outside of
his/her country of nabonality
for S years or more?
O yn ®No
Profession/Occupation:
)SC Interiors LLC
Tax ID / $SN:
Current Employer:
JSC Interiors LLC
PositionMtle/Rank:
Interior Decorator
Address of employer:
AS Lexington Ave 14th Fl New York NY United States 10022
Does the person work a senior executNe of a DB-recognized regulated entity in the financial
ndusby7 or an entity listed on a 06-recognised exchange' (riot applicable for operating
entities
OTOS ®No
Is the individual a Politically Exposed Person (PEP)'(# Yes, desert.)
OYU
®No
To the best of your knowledge, is the individual related to an employee of the DB group(/'
Fara* or Friendship, desenbe)
O Fent
ElFriendshlp
rd None
To the best of your knowledge, is the indrOdual party to a non-banking relabonshg with
Deutsche Bank (e.g., external legal counsel, client referral source, supplier of goods or
servxes),(6 Yes,descnbe)
O Yes
No
If appkable, indicate which bank officers have met the
person:
Indicate sphere and %glen the client meeting (s) took place:
Bank Officer Name(s)
me(s)
Bank Office:
Client pirate
Degnicile.
Client Place of
Business:
Other Location (specify):
Stewart %Meld
O
g
6/23/2017
•
El
O
11
r-i
E
ri
for this individual are not filled in, because they are the same as for the fob:ming person:
• Wealth Details
3B. Wealth Details (Only for parties reguinrg source of wealth description as odcated in Section 2)
Nature of the Individuals Business:
intenor design
Pnmary Country of source of wealth/source of Funds'
Primary industry of source of Wealth/Source of Funds'
Summanze Source of Wealth:
• Business Owner RI Salary/Earnings O Investment O Inheritance/Gifts ['Other:
Further Describe Source of Wealth /Detail the history of vdealiR for each of the sources: (e.g. For trusts, how did settke accumulate wealth? For inheritance,
how did family accumulate iwalth'For business owners, hot
In business, how many empayees, level of profitability? Indicate type el basin
In
ntries of major activities, important business partners.)
went to school for interior design and now works as a interkx decorator for
a currently client of D8 (kyc case 01305519). Her annual income is approximatety 4150k with salary, bonus, and cannessicen.
Estimated Annual Income(S):
150.000M
Estmated amount of investable assels($):
<$1 SW
Estimated Net Worth(S):
<$1 Nim
Amount of assets planned to invest wth PWM($):
2000.00
Other Known Financial Institutions:
Institution:
did
I
I use
Est. Assets Under Mgt:
2,000.00
Insbbibon:
JP Morgan Chase
County:
USA
Est. Assets Under Mgt
2,000.00
SDNY_GM_00040065
Ilttps://dbforcepb.my.salesforcCLINEJIDEArdiAlL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0002889
EFTA_00150674
EFTA01284152
KYC Print
Page 6 of 10
bsteutice:
I
Meese Indicate the family
Country
Est Asseb Under Mgt:
tuabon of the individual (martal status, other Carney members, etc.):
SDNY_GM_00040066
littps://dbforcepb.my.salesforcalNEJIDEschiltiN0000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED R CRIM. P. 6(e)
DB-SDNY-0002890
EFTA_00150675
EFTA01284153
KYC Print
Page 7 of 10
DB PWM GLOBAL KYC/NCA: US/LatAm/Int'I PART B
Relationship Name
SOUDERN FINANCIAL RELATIONSHIP
Risk Rabng Comments:
Booking Center
2 NY
NY/ Offshor
E Offshore
RiskO Moderate n1
ci High Risk
Yoonsun Chung
(Compliance *nature)
O DB Employee
O CEr Managed PIC
• DB is Trustee/Co-Trustee
O Bearer Shares
4. Attachments
A. Type of Photo ID Provided
El Drivers license O Passport O National/State ID O Other
B. Checklist of names 0ndivkluals and/or entities) that were submitted for database searches is
attached
O Yes 74 No
C. Please indicate the results of the database searches performed
RDC searches complete
2 Yes O No
negative results found
O yes tri No
PCR checks complete
2 Yes O No
negative results found
O Yes
No
OFAC checks complete
2 Yes O No
negative results found
O yes 0 No
BIS searches complete (Leds/Nexis, Facttva, Reuters, Dow Jones, ChB)
2 Yes O No
negative results found
• yes Fa No
Denial Orders checks complete
2 Yes 0 No
negative results found
0 Yes 2 No
Martindale-Hubbell searched (LawyersAaw Arms orgy)
0 Yes 2 No
negative results found
0Yes • No
D.
Please summarize any negative results from the database searches indicated above:
No Negative Media
Court case referencing
of Pennsylvania against Bayer Eswre Inc is fora personal injury and is a false positive as the
in the
KYC resides n New York and has no current injuries.
No Negative Media
No Court Cases
NES, I1C:
Previous!). KYC approved. See Case #:01141322 for relevant attachments
E. To the best of your knowledge, has the client ever been convicted of a criminal offense?
O yes gt No
F.
To the best of your knowledge, has the customer ever been involved in any past (ligation again
Deutsche Bank AG or any of is subsidiaries or is the customer threatening litigation against
Deutsche Bank AG or any of in subsidiaries? af Yes, provide data* below and contact Qualify
O Yes RI No
AV* an falahtf) or fhe Regulatory Control Group and notdy analance immediately)
G. Does the client or related party have any financial or other association / interactions within
countries or regimes sanctioned by the Office of Foreign Assets Control (MC)?
0 Yes 2 No
H. Does the client or related party have any financial or other association/ interactions within high
O yes g No
risk countries?
I. Corporate Documentation Attached (Legal Entitles Only)
2 Yes • No • Not Applicable
3. Undisclosed Principal Poem Complete (Intermediaries Only)
0 yes 0 No 2 Not Applicable
K. If Lexis/Nexis Search Results, Corporate Documents or Other Supporting Documentation Is net in English, please provide an English summary of the
nature/contents of the non-English Documentation:
L. Special Risk Factors
Does the account have Nexus to Special Risk Couritries?
O Yes El No
Is the account shoran unusually complex?
0 Yes Ira No
SDNY_GM_00040067
https://dbforcepb.my.salesforcaraNtErilDnEgISAIdIAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0002891
EFTA_00 I 50676
EFTA01284154
KYC Print
Page 8 of 10
Is there any IndkatIon the client set up a non operating company
expressly for the purpose of transfening shares to third parties'
El yes ONO
Is there any Indication this could be a prohibited business relationship'
K Yes EZNo
Are the bearer shares Identified subject to acceptable antrdss
O yes ©No
SONY_GM_00040068
https://dbforcepb.my.salesforeCLINErilEIEJNITIAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0002892
EFTA_00 150677
EFTA01284155
KYC Print
Page 9 of 10
M. Case Comments
Created By
Date
Comments
The account holders have been cknts of DB since 2013. Below are the reasons why we were comfortable
with approving this high risk KYC remediatlon -
• Information and supporting documents required by our AML Policy were provided and reviewed; and as a
result, we have an understanding of the structure of the accountholders, their purpose, the purpose of the
account and expected transacbon actr2
• The account holders
M=I
source cf wealth and source of funds were
Kshitg Golan
7/27/117 5:06 PM
sufficiently detailed and appears plausible
• Negatke Media: One of the account holders,
used to work for Jeffrey Epstein. Jeffrey Epstein
s a registered sex offender. In June 2008, under a plea deal, he was sentenced to 18 month for soliciting a
minor. He served 13 months. See approval from Chip Packard under KYC 01082293.
• Our review did not identrfy any red flags and thus there vas no need to escalate this case further.
• We performed due diligence searches on all parties and did not find the names searched to be on any
/sanctions lists.
ONSHORE APPROVALS
Client Facing Professional (CFP):
stewart °Wield
(Signature)
stewart oktheld
720:2017
atce Director/Business Head'
Andrew F Gallivan
(Signature)
Andrew F Gal van
7/25.2017
Regional Office Director:
(Signatue)
AM Business Risk:
(Signature)
AML Compliance:
Kshrb) Golan,
Yoonsun Chung
(Signature)
Kshitg Golani
Yoonsun Chung
7/27/2017
7/27/2017
LATAM/INTERNATIONAL APPROVALS
Client Facing Professional (CFP):
(Signature)
Account Manager.
(Signature)
Global Market Team Head
(GMTH)/Sub.hiarket Team Head
(SNTH):
(Signature)
AML Business Risk:
(Signature)
AML Compliance:
(Signature)
PRIVATE WEALTH MANAGEMENT POLICY STATEMENT: Deutsche Rank Private Wealth Management
(PWAI) worldwide is committed to professionally serve the interests of its clients. To do so. Client Facing
Professionals I(I) (CFP.9 should establish and maintain business relationships only with persons who satisfy our
high standards of.suitability. background and character. Due diligence obtained on the client must be appropriately
documented by the CFP. It is the responsibility of CFP's to demonstrate that they know their client both at the
SDNY_GM_00040069
https://dbforcepb.my.salesforcaaNErt DiErNilliA10000000D9Ditice... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0002893
EFTA_00 150678
EFTA01284156
KYC Print
Page 10 of 10
inception of a relationship and on an ongoing basis.
DECLARATION FOR ALL SIGNERS OF THIS FORM:• To the best of my knowledge and belief the above
information is correct and up to date. 1 confirm that I have no suspicions relating to the money laundering or
unethical activities on the part of the client(s) and that 1 have followed all the procedures relating to account opening
as described in the PWM Americas Procedures and the PWM Global KYC Policy
(1) Client Facing Professionals (CFP is) include: Relationship Managers. Wealth Advisors. Product Officers,
Brokers, Client Managers, etc.
Deutsche Bank Americas New York VA
SONY_GM_00040070
hups://dbforcepb.my.salesforcaliNtErilDaiLIJIAL000000D9Di&e...
7/30/2019
CONFIDENTIAL -PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0002894
EFTA_00150679
EFTA01284157
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