Text extracted via OCR from the original document. May contain errors from the scanning process.
Cynthia Rodriguez
From:
Patrick Campion
Sent:
Thursday, January 05, 2017 3:46 PM
To:
Cynthia Rodriguez
Cc:
Samantha Harmon; Armen Brash
Subject:
RE: APPROVAL NEEDED: High Risk KYC Case 01704382 [Ij
Classification: For Internal use only
Approved
Kind regards,
Patrick Campion
Patrick Campion
Managing Director I Head of Wealth Management Americas
Deutsche Bank Trust Company Americas
Wealth Management - Americas
345 Park Avenue. 10154-0004 New York. NY. USA
Cc: Samantha Harmon; Armen Brash
Hello,
I am requesting Exco Approval for a new account opening for current DB client Jeffrey Epstein.
RM Name
Business Line
GCIS # / KYC #
New or Existing
Relationship?
If yes. please include relationship
since date. approx # of accounts.
AUM. etc.)
Stewart Oldfield
US Onshore
Existing relationship since 8/26/2013. A total of 21 deposit accounts and 3 money
market accounts for multiple entities, 5 brokerage accounts and 1 custody account.
Total AUMs $224mn.
Legal name of Account
Prytanee, LLC
Holder(s)
Name of UBO(s)
Jeffrey Epstein and Caroline Lang
(Please include UBOs who own
1
SDNY_GM_00065110
DB-SDNY-0027935
EFTA_00I756l0
EFTA01299272
25% and more: It there are multiple
layers. please include description
of ownership structure)
Description of Type of
account being opened
with detailed purpose
of the accounts
(Please include SOW information/
Geographic location/
For Entity Accounts: Description of
the entity and background
information on the UBO)
Reason for High Risk
PEP (Y/N)
If yes. include details
Any negative media
and/or court cases?
Include ALL negative media &
court cases
If Yes, please give details
Business Justification
for the relationship
despite High Risk
Factors
Kind regards,
Cynthia Rodriguez
Cynthia Rodriguez
Assistant Vice President
We are opening a deposit account for Prytanee LLC. The account will be used to
purchase art from up and coming artists.
This relationship is deemed high risk due to multiple court cases on Jeffrey Epstein,
involving 22 April 2004 SEC filed a settled civil fraud action for illegal insider trading
in three publicly traded Massachusetts banks. Final judgement permanently enjoins
him from violating the antifruad provisions and he agreed to pay a total of
S72532.06 in disgorgement of trading profits, prejudgment interest and civil
penalties. Epstein was sentenced to 21 months in federal prison for three counts of
fraud, sexually assaulting a girl and solicitation of prostitution. These alerts were
previously approved by senior management and AML Compliance. Prior clearance
is attached as a reference
No
Yes
Aside from the court cases listed in the reason for high risk, all other alerts were
false positives and no new court cases or negative media has come up for this
client.
All negative media and alerts have been reviewed by AML Compliance and they do
not see a reason to discontinue the existing relationship with Jeffrey Epstein.
Deutsche Bank Trust Company Americas
Deutsche Asset & Wealth Management
345 Park Avenue, 10154-0004 New York. NY. USA
2
SDNY_GM_00065111
CONFIDENTIAL - PURSUANT TO FED. R.ctailf
IDENTIAL
DB-SONY-0027936
EFTA_00I75611
EFTA01299273
SON,M_00065,2
CONFIDENTIAL- PURSUANT TO FED. R.cONEIDENTIAL
DB-SONY-0027937
EFTA,I756I2
EFTA01299274