Case File
efta-01402031DOJ Data Set 10OtherEFTA01402031
Date
Unknown
Source
DOJ Data Set 10
Reference
efta-01402031
Pages
20
Persons
0
Integrity
Extracted Text (OCR)
EFTA DisclosureText extracted via OCR from the original document. May contain errors from the scanning process.
Subject: RE: Southern Financial LLC - KYC and credit derivatives/convertible
bonds onboarding [C]
From: Martin Zeman
Dat-•
w.
o :
.o:.
o400
To:
Cc:
Classification: Confidential
Zack — thanks, please keep the foot on the pedal.
Also, adding Nina Tona who I forgot to include on last email.
From: Zack Bunimovich
Sent: Thursday. March 15. 2018 12:29 PM
Classification: Confidential
Classification: Confidential
Hi Martin,
EFTA01402031
I'm verifying with the KYC team that the provided documents and the
information below fulfills all of the requirements. We have this account set
as one of the highest priorities in our pipeline, so operational setups will
be focused on as soon as this piece is settled.
Thanks,
Zack
From: Martin Zeman
Sent: Wednesday, March 14, 2018 5:09 PM
suoject: soutnern rinanclal LU. - KYI. ana cream a
crea1L aerlvatives/convert1DLe
bonds onboarding [C]
Importance: High
Classification: Confidential
Zack,
See attached for what Nina Tona sent in the last email in this chain and I
am adding the Formation Document. This should complete everything you asked
for in your email from March 13.
We have a pending trade with the client in credit derivatives next week. Can
you please put this as a priority?
Source of Wealth:
The source of wealth is Jeffrey Epstein as the sole shareholder. Jeffery
Epstein began his financial career in 1976 as an options trader at Bear
Stearns and became a partner in 1980. In 1982, Epstein founded his own
EFTA01402032
financial management firm, 3. Epstein & Co., managing the assets of clients
with more than a billion in net worth. In 1996, Epstein changed the name of
his firm to The Financial Trust Company and based it on the island of St.
Thomas in the US Virgin Islands, which merged into Southern Financial LLC.
All of his clients were anonymous except for the very wealthy businessman
Leslie Wexner. His wealth has come from his days at Bear Stearns and his
financial management firms.
Client Contact:
Richard Kahn
Formation Document:
Attached LLC Documents include the Articles of Organization,
Thanks,
Martin
From: Nina Tona
Sent: Tuesday, March 13, 2018 11:41 AM
Subject: RE: SF [I] [C]
Classification: Confidential
EFTA01402033
Zack,
I believe some of the below was already provided back in Feb. Please review
below and attached to make sure they are sufficient and we'll get back on
the additonal.
Ownership - Broken down to 10% (Org chart with %'s of ownership
or confirmation from Senior Client Rep explaining the ownership breakdown)
Legal Reps — Identify and Verify
UBO's - Identify and Verify
Source of Funds — Identification & Verification (Annual Report)
Source of Wealth — Identify and Verify
Client Contact for Patriot Act disclosure email
Formation Document (Cert of Incorp, etc)
Nature of Business Doc
Organization Chart
o
Per attachment "Southern Financial Operating Agreement" (pages 1, 16)
§ Southern Trust Company Inc. is the sole member of Southern Financial LLC
§ Jeffrey Epstein is the sole shareholder of Southern Trust Company Inc.
UBOs (Owners) that own greater than 10%
o
Jeffrey Epstein is the sole UBO (see "Organization Chart" above)
EFTA01402034
The source of funds for the UBOs (owners) that are greater than
10%
o
Jeffery Epstein began his financial career in 1976 as an options trader
at Bear Stearns and became a partner in 1980. In 1982, Epstein founded his
own financial management firm, J. Epstein & Co., managing the assets of
clients with more than a billion in net worth. In 1996, Epstein changed the
name of his firm to The Financial Trust Company and based it on the island
of St. Thomas in the US Virgin Islands, which merged into Southern Financial
LLC. All of his clients were anonymous except for the very wealthy
businessman Leslie Wexner. His wealth has come from his days at Bear Stearns
and his financial management firms.
List of Legal representatives
o
Per attachment "Southern Financial Operating Agreement" (pages 16)
§ Jeffrey Epstein, Darren K. Indyke, Richard Kahn
Annual report
o
See attachments "Southern Financial LLC Financials June 2017" and
"Southern Trust Company Inc. Financials June 2017" for latest financial
statements
Thank you
Nina Tona
From: Zack Bunimovich
Sent: Tuesday, March 13, 2018 11:16 AM
EFTA01402035
Subject: RE: SF [I] [C]
Classification: Confidential
Hi Martin,
I just received the finalized KYC review yesterday. Even though the entity
is opened for other products, it is outside of its KYC review date and is
triggering a high risk rating. In order to approve the account, the team
will need the following:
Ownership - Broken down to 10% (Org chart with %'s of ownership
or confirmation from Senior Client Rep explaining the ownership breakdown)
Legal Reps — Identify and Verify
UBO's - Identify and Verify
Source of Funds — Identification & Verification (Annual Report)
Source of Wealth — Identify and Verify
Client Contact for Patriot Act disclosure email
Formation Document (Cert of Incorp, etc)
Nature of Business Doc
Thanks,
Zack
From: Martin Zeman
Sent: Monday, March 12, 2018 10:19 AM
EFTA01402036
Subject: RE: SF [I] [C]
Classification: Confidential
Morning Zack,
We haven't heard back from you on Friday. Can you let us know what the
timeline looks like today please?
Thanks,
Martin
From: Zack Bunimovich
Sent: Friday. March 09. 2018 11:30 AM
Subject: RE: SF [I] [C]
Classification: Confidential
Xavier,
The fund was still undergoing a KYC review per my last contact with the
team. I will check again today.
Thanks,
EFTA01402037
Zack
From: Xavier Avila
Sent: Friday. March 09. 2018 10:32 AM
Subject: Re: SF [I]
Zack, what is the status on this urgent request?
Xavier Avila
Managing Director
Deutsche Bank Securities Inc
Mobile:
Email:
On Mar 5, 2018, at 15:09, Martin Zeman
wrote:
Classification: For internal use only
Zack,
Please go ahead and set them up for credit derivatives as well as
convertible bonds. The credit derivatives is a priority and rather urgent.
Client is ready to trade.
EFTA01402038
Thanks
Martin
From: Nina Tona
Sent: Monday, March 05, 2018 3:07 PM
Subject: RE: SF [I]
Classification: For internal use only
Martin — Please confirm we don't need SF to be extended for anything else
besides credit derivatives and the products already onboarded.
Thank you
Nina Tona
From: Zack Bunimovich
Sent: Monda , March 05, 2018 12:58 PM
u.ject:
EFTA01402039
Classification: For internal use only
Hi Xavier,
Nothing else is needed from your end at the moment. I will send this request
to the KYC team for review and then setup. Can you confirm Credit
Derivatives is the only necessary extension? I know Convertible Bonds were
also in the discussion.
I see the BR 1007494283 set up for a decent amount of products already. See
below.
<image001.jpg>
Thanks,
Zack
From: Xavier Avila
Sent: Monda
March 05. 2018 11:45 AM
u'ject: • •
Thanks Rita.
Zack, let us know what next steps are.
EFTA01402040
From: Rita Shteynberg
Sent: Monday. March 05. 2018 11:08 AM
Subject: RE: SF [I]
Including Zack who will be the case manager on this.
From: Xavier Avila
Sent: Monday, March 05, 2018 10:59 AM
Subject: RE: SF [I]
Hi Rita/Mat, let us know what we need to extend SF to Credit Derivatives as
the client is still live in one trade they want to execute.
Thanks
From: Rita Shteynberg
Sent: Friday, March 02, 2018 12:41 PM
Subject: RE: SF [I]
EFTA01402041
Thanks for the confirmation. We will proceed with the onboarding.
From: Mathew Negus
Sent: Friday, March 02, 2018 12:34 PM
Subject: RE: SF [I]
I'll take this one for Jitan.
As CIB green please proceed with the NCA process and the inherent KYC update.
Thank you
Mathew Negus
Director I ICG Business Management
From: Nina Tona
Sent: Friday,
Mel
To: Jane Varley
avier Avila
EFTA01402042
u'ject•
•
Importance: High
Classification: For internal use only
Jane — NCA is still in progress. Rita and her team are working on it. They
stopped the NCA once they found out it was in red. Jitan will inform them
now to complete the NCA.
@Jitan — Please inform Rita to continue with the NCA.
Thank you
Nina Tona
From: Jane Varley
Sent: Friday, March 02, 2018 11:04 AM
Subject: RE: SF [I]
Classification: For internal use only
EFTA01402043
+Aziz and Tanu
Hi Monika,
This was a WM US retain from the Offboarding Clearing House process, that
currently reflects in the overall CIB file colour (not coverage colour).
Hence green.
Nina — was NCA completed? We can't see it reflected in dbCAR (still appears
delinquent) but I know that is part of the broader conversation that Julia
is having with Paul Chapman.
Thanks
Jane
From: Monika Valantiejute On Behalf Of GM ACO
11111111
Subject: RE: SF [I]
Classification: For internal use only
Hi Xavier
The GB adoption location is Red across all business but this is CIB Green
EFTA01402044
for the US adoption location — as one of the businesses has asked to retain
this. @Jane please confirm which business asked to retain?
In these instances, the GM products will not be offboarded if another
business has asked to retain and the KYC/ACO responsibility sits with that
business.
However, please also be aware that this is a High Risk client which is KYC
deficient and was last reviewed in 2015.
Please let me know if any other questions.
Kind regards,
<image002.png>
Monika Valantiejute
GM Project Mercury
Deutsche Bank
Winchester House, 1 Great Winchester Street, London, EC2N 2DB
Email
EFTA01402045
From: Xavier Avila
Sent: 02 March 2018 13:53
Subject: RE: SF [I]
Thanks Monica, did we hear anything back? The client is asking questions and
we have no clear answers or timeframe to give him. Thanks
Xavier Avila
Managing Director
Deutsche Bank Securities
From: GM ACO
Date: Thursday, Mar 01, 2018, 15:09
Subject: RE: SF [I]
EFTA01402046
Classification: For internal use only
Hi Xavier
I've reached out to Central Mercury to find out the CIB colour - I will
update as soon as I hear back.
Kind regards,
<image002.png>
Monika Valantiejute
GM Project Mercury
Deutsche Bank
Winchester House, 1 Great Winchester Street, London, EC2N 2DB
Email
uoject:
EFTA01402047
GM ACO, can you pls let us know what the issue is?
We have a client trying to execute a transaction.
Thanks
From: lain Macara
Sent: Thursday. March 01. 2018 11:48 AM
Gm ACO — can you liaise with central merc and establish the CIB colour on
the rhp below?
thx
From: Xavier Avila
Subject: SF
EFTA01402048
Ian, thanks for the call.
So Rita who is the Case Manager seems to suggest that she sees Southern
Financial Red and therefore we cannot extend it to Credit Derivatives, while
we think we should see this Green from a KCP perspective.
Bu you explain to me that the Red might be only when it comes to your ICG
world.
Can you pls clarify if this client is Red for everyone including KCP and if
so how do we turn it Green, as discussed this is an example of a KCP
Americas account that is ACOed by us, in this case myself.
Thanks
Xavi
From: Nina Tona
Sent: Thursday, March 01, 2018 11:00 AM
To: Xavier Avila <[email protected]>
Subject: SF
<image003.png>
Kind regards,
<image004.gif>
Nina Tona
Associate
Business Control Manager, Key Client Partners — Americas
Deutsche Bank Wealth Management
EFTA01402049
5022 Gate Parkway
Jacksonville, Florida 32256
Tel.
Email
KCP products and services are intended and available only for persons who
are sophisticated institutional investors within the meaning of the FINRA
Rule 4512(C)(3), and who are capable of evaluating the strategies,
characteristics and investment risks of, and exercising independent judgment
in evaluating, the ideas and products discussed herein. Trades and
transactions are subject to relevant internal approvals of DBSI or its
affiliates prior to execution, and the execution of any transaction or idea
discussed herein is conditional on your becoming a client of Deutsche Bank.
Key Client Partners (KCP) products, investment ideas and solutions and
related matters discussed herein are provided for discussion purposes only,
and strictly on a non-advisory basis. The KCP Americas desk does not provide
investment advice.
The information set forth herein is confidential and personal to you and is
being presented for your information and for discussion purposes only. Any
reproduction and/or redistribution thereof (in whole or in part) or
disclosure of its content without our written consent is strictly
forbidden. This communication does not create any legally binding
obligation on the part of DBSI or any of its affiliates.
EFTA01402050
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