EFTA01409514

Case: 01082293 — salesforce.com - Unlimited Edition Page 1 of 9 Ti Close Window Ti Print This Page g Expand All I Collapse All Case: 01082293 Relationship Details Relationship Name EPSTEIN, JEFFREY RELATIONSHIP Primary Officer Paul Morris Reason for KYC New Client Wealth Details Same for All Parties Status 6. Approved Office New York Reason for Update (If Applicable) Reason for Rejection (If Applicable) 1. Please change account opening dates; these are in the past. RESOLVED 2. Please mark the accounts legal entity/corporate accounts. RESOLVED 3. Please give a more substantial explanation of how the client was introduced; how did Paul meet Jeffrey in the first place. RESOLVED 4. The source of wealth description is not sufficient; please give a more detailed bio/narrative on his source of wealth with employer names/positions held, salaries, etc. The SOW description should include an explanation of how he got started, and how he got to where he is today. RESOLVED 5. For the entities, please give a bette description of exactly what they do... the purpose of entity/nature of business provided is not sufficient. RESOLVED 6. Please attach full searches on the previous name of the company. RESOLVED 7. According to the shareholder info attachment; Southern Trust Company Inc is the sole member of Southern Financial LLC; and Jeffrey is the sole shareholder of Southern Trust Company Inc. Therefore, the KYC hasn't been set up correctly to reflect EFTA01409514 this set up. RESOLVED 8. Please attach the LLC operating agreement for Southern Financial LLC this should also include proof of ownership/control. RESOLVED 9. Please attach the articles of incorporation and if available, bylaws for Southern Trust Company Inc. RESOLVED 10. Please also attach full searches on Financial Trust Company Inc; which merged into Southern Financial LLC. RESOLVED 11. Please attach all alerts and alert clearances. RESOLVED Some issues above were not resolved and there is a new issue below: 1. Please attach full searches on J. https://dbforcepb.my.salesforce.com/5006000000Qah5L/p?retURL=/- 5006000000Qah5LA... 8/28/2015 EFTA01409515 Case: 01082293 — salesforce.com - Unlimited Edition Page 2 of 9 Epstein & Co. as this was a company started and controlled by Mr. Epstein. RESOLVED all issues resolved Moderate Risk High Risk Relationship Number 00000483290 DB Pay for Third Case Owner Approved KYC No party for introduction Describe, Third party compensation Reason for Rush (If applicable) Exception Expires Reason for Exception (If Applicable) Booking Location NY How Client Was Introduced Introduction Details Prospect Jeffrey Epstein was a client of Paul's a JP Morgan. Paul and Jeffrey Epstein had a mutual friend/colleague who introduced them while Paul was at JPMorgan. Over the course of a few meetings Paul was able to get Jeffrey to bring some of his funds over to JPMorgan Request Temporary/Permanent Exception Special Client Type (select if applicable) DB Employee DB is Trustee/CoTrustee Custom Links Import Documents Export Documents View Documents From Repository A. Type of Photo ID Provided A. If Other, Type of Photo ID Provided B. Checklist of names (individuals and/or entities) that were submitted for database searches is EFTA01409516 attached B. Yes C. Please indicate the results of the database searches performed Yes - Negative Results Found RDC searches complete OFAC checks complete Denial Orders checks complete Yes - No Negative Results Found Yes - No Negative Results Found KYC Wizard Launch Due Diligence View Due-Diligence Case-Report Global KYC Print Please rush. Client wants to fund accounts ASAP. DB Managed PIC Bearer Shares? U.S. Drivers License; Passport PCR checks complete BIS searches complete Martindale-Hubbell searched Yes - Negative Results Found Yes - No Negative Results Found Not Applicable https://dbforcepb.my.salesforce.com/5006000000Qah5L/p?retURL=/- 5006000000Qah5LA... 8/28/2015 EFTA01409517 Case: 01082293 — salesforce.com - Unlimited Edition Page 3 of 9 D. Please summarize any negative results from the database searches indicated above D. JEFFREY EPSTEIN: RDC Alert #1 -- Cleared & APPROVED by Chip Packard, AML Compliance, and Pat Harris PCR Alert #1/2 -- Not our client All Cases Closed SOUTHERN FINANCIAL LLC: No negative media No court cases SOUTHERN TRUST INC: No negative media Court Case -- Not our client. FINANCIAL INFOMATICS INC: No negative media No court cases J. Epstein & Co. All Negative Media is our client. He has been cleared of posing a reputational risk as shown by the AML Clearance attached Court Cases have been closed FINANCIAL TRUST & CO RDC/PCR alert is associated with Southern Financial, the company it merged into. This alert has been cleared by Compliance and is attached Court Cases are closed E. Has the client or related party ever been convicted of a criminal offense? E. Yes F. Has the client or related party ever been involved in any past or threatened litigation against Deutsche Bank AG or any of its subsidiaries? F. No G. To the best of your knowledge, does the customer have any financial association/interaction, e.g. maintain homes or companies, etc., within the countries and regions, or is the customer associated with the regimes or organizations that.. G No H. Does the client or related party have any financial or other associations/- interactions within countries that pose a risk of money laundering? H No I. Entity Documentation Attached I Yes J. Intermediary form approved by AML compliance? (intermediaries only) Not Applicable K. If any documentation is not in English, please provide an English summary or translation EFTA01409518 Summary https://dbforcepb.my.salesforce.com/5006000000Qah5L/p?retURL=/- 5006000000Qah5LA... 8/28/2015 EFTA01409519 Case: 01082293 — salesforce.com - Unlimited Edition Page 4 of 9 Approvals Primary Officer/RM Approver AM Approver (Int'l Only) Office Dir./Bus. Head/GMTH/SMTH Approver Regional Office Director Approver AML & Business Risk Approver AML & Business Risk Approver II Compliance Approver Compliance Approver II Janice Franklin Armen Brash Brian M. Biggar Paul Morris Primary Officer/RM Approval Date AM Approval Date (Int'l Only) Office Dir./Bus. Head/GMTH/SMTH Date Regional Office Director Approved Date AML & Business Risk Approved Date AML & Business Risk Approved Date II Compliance Approved Date Compliance Approved Date II *** REMINDER--You must check the active assignment box below to route to the office director Disregard the below fields Contact Name Jeffrey Epstein Subject Contact Information Name Jeffrey Epstein Customer Name Epstein, Jeffrey Nickname EFTA01409520 *Marital Status Gender * SSN 090-44-3348 * Federal Tax ID # Birthdate Date of Death Relation to Customer Primary Main Contact Contact Name at Company Custom Links Self 1/20/1953 8/21/2013 8/20/2013 7/18/2013 7/17/2013 Priority Description High Contact Owner Last Modified By Created By Paul Morris Relational Junction, 3/2/2015 4:43 AM Tanuj Sharma, 4/18/2013 11:30 AM Customer Number 00000483289 Status Active Bank 1 Vantive Owner Type eSign Compliant Email Individual https://dbforcepb.my.salesforce.com/5006000000Qah5L/p?retURL=/- 5006000000Qah5LA... 8/28/2015 EFTA01409521 Case: 01082293 — salesforce.com - Unlimited Edition Page 5 of 9 View Customer Accounts & Revenue Request to be Deleted Launch Due Diligence Update KYC Contact Conversion Request Create KYC Show KYC's BIS Research Request Template Phone and Email Primary Phone Type Phone Home Phone Business Phone Mobile Other Phone Other Description Privacy Information Mailing Restrictions Do Not Call Address Information Mailing Address Type Business * Business Name Southern Financial LLC * Position/Title/Rank President Mailing Address 6100 Red Hook Quarter B3 St. Thomas, 00802 USVI Additional Address Information Other Address 2 Type Other Address 2 Other Address 3 Type Other Address 3 Legal Address (TEAS Ticket required to change Legal Address) * Legal Street Litte Saint James * Legal City * Legal State * Legal Zip Code 00802 Saint Thomas Other Address Type * Other Business Name * Other EFTA01409522 Position/Title/Rank Other Address Litte Saint James Saint Thomas, 00802 US Virgin Islands Primary Residence Map View Due-Diligence CaseReport Email Email2 Website Asst. Phone Assistant Fax * Country of Citizenship (Individual) * Country of Residence (Individual) USA USVI https://dbforcepb.my.salesforce.com/5006000000pah5L/p?retURL=/- 5006000000pah5LA... 8/28/2015 EFTA01409523 Case: 01082293 — salesforce.com - Unlimited Edition Page 6 of 9 * Legal Country Salutations Prefix: Formal - Couple Salutation: Formal - Couple Prefix: Formal - Solo Salutation: Formal - Solo Prefix: Informal - Couple Salutation: Informal - Couple Contact Description, Interest and Hobbies Marketing Interests Description Personal Interests Additional Party Information *Profession/Occupation * Nature of Individuals Business Self Empolyed Private investments *Is Indv/Entity a PEP (or associated)? * If Yes, describe PEP *Family Relationship to DB Employee * If Yes, details of Relationship KYC Related Parties Epstein, Jeffrey KYC Party Contact Jeffrey Epstein Type Individual contributes to account or wealth Account Holder Southern Financial LLC KYC Party Contact Southern Financial LLC Type Entity contributes to account or wealth Account Holder Southern Trust Company, Inc. KYC Party Contact Southern Trust Company, Inc. Type Entity contributes to account or wealth Account Holder EFTA01409524 None No Prefix: Informal - Solo Salutation: Informal - Solo Prefix: Other Salutation: Other US Virgin Islands Spouse / Children Education https://dbforcepb.my.salesforce.com/5006000000Qah5L/p?retURL=/- 5006000000Qah5LA... 8/28/2015 EFTA01409525 Case: 01082293 — salesforce.com - Unlimited Edition Page 7 of 9 KYC DB Accounts Southern Financial, LLC Southern Financial, LLC Southern Trust Company, Inc. Southern Trust Company, Inc. KYC Related Party Roles Southern Trust Company, Inc. KYC Party Contact Jeffrey Epstein Role Signatory or Full POA Please Describe Sole shareholder of Southern Trust Last Modified Date 8/21/2013 Southern Trust Company, Inc. KYC Party Contact Jeffrey Epstein Role Signatory or Full POA Please Describe Sole shareholder of Southern Trust Last Modified Date 8/21/2013 Southern Financial, LLC KYC Party Contact Jeffrey Epstein Role Signatory or Full POA Please Describe Sole shareholder of Southern Trust Last Modified Date 8/21/2013 Southern Financial, LLC KYC Party Contact Jeffrey Epstein Role Signatory or Full POA Please Describe Sole shareholder of Southern Trust Last Modified Date 8/21/2013 Southern Trust Company, Inc. KYC Party Contact Southern Trust Company, Inc. Role Account Holder Please Describe Last Modified Date 5/28/2013 Southern Trust Company, Inc. KYC Party Contact Southern Trust Company, Inc. Role Account Holder Please Describe Last Modified Date 5/28/2013 Southern Financial, LLC KYC Party Contact Southern Financial LLC Role Account Holder Please Describe https://dbforcepb.my.salesforce com/5006000000Qah5L/p?retURL=/- 5006000000Qah5LA... 8/28/2015 EFTA01409526 Case: 01082293 — salesforce.com - Unlimited Edition Page 8 of 9 Last Modified Date 5/28/2013 Southern Financial, LLC KYC Party Contact Southern Financial LLC Role Account Holder Please Describe Last Modified Date 5/28/2013 Southern Financial, LLC KYC Party Contact Southern Trust Company, Inc. Role Significant Shareholder(>=25%) Non-PIC Entity (Indicate ownership %) Please Describe Southern Trust is the sole member of Southern Financial and Jeffrey Epstein is the sole shareholder of Southern Trust Last Modified Date 8/14/2013 Southern Financial, LLC KYC Party Contact Southern Trust Company, Inc. Role Significant Shareholder(>=25%) Non-PIC Entity (Indicate ownership %) Please Describe Southern Trust is the sole member of Southern Financial and Jeffrey Epstein is the sole shareholder of Southern Trust Last Modified Date 8/14/2013 Case History 8/21/2013 11:31 AM User Janice Franklin Action Changed Case Owner from Compliance KYC to Approved KYC. 8/21/2013 11:31 AM User Janice Franklin Action Changed Compliance Approver to Janice Franklin. Changed Status from 5. Ready for Compliance Approval to 6. Approved. 8/20/2013 2:59 PM User Armen Brash Action Changed Owner (Assignment) from AML & Business Risk to Compliance KYC. Changed Reason for Rejection (If Applicable). Changed AML & Business Risk Approver to Armen Brash. Changed Status from 4. Ready for AML & Bus. Risk Approval to 5. Ready for Compliance Approval. 8/20/2013 9:36 AM User Armen Brash Action Changed Reason for Rejection (If Applicable). 8/15/2013 1:59 PM User Amanda Kirby Action Changed Case Owner from Amanda Kirby to AML & Business Risk. 8/15/2013 1:59 PM User Amanda Kirby Action Changed Status from Rejected to 4. Ready for AML & Bus. Risk Approval. EFTA01409527 8/14/2013 4:44 PM User Armen Brash Action Changed Case Owner from AML & Business Risk to Amanda Kirby. https://dbforcepb.my.salesforce.com/5006000000Qah5L/p?retURL=/- 5006000000Qah5LA... 8/28/2015 EFTA01409528 Case: 01082293 — salesforce.com - Unlimited Edition Page 9 of 9 8/14/2013 4:44 PM User Armen Brash Action Changed Reason for Rejection (If Applicable). Changed Status from 4. Ready for AML & Bus. Risk Approval to Rejected. 8/13/2013 5:42 PM User Amanda Kirby Action Changed Case Owner from Amanda Kirby to AML & Business Risk. 8/13/2013 5:42 PM User Amanda Kirby Action Changed Status from Rejected to 4. Ready for AML & Bus. Risk Approval. 7/22/2013 3:20 PM User Armen Brash Action Changed Case Owner from AML & Business Risk to Amanda Kirby. 7/22/2013 3:20 PM User Armen Brash Action Changed Reason for Rejection (If Applicable). Changed Status from 4. Ready for AML & Bus. Risk Approval to Rejected. 7/18/2013 2:58 PM User Brian Biggar Action Changed Owner (Assignment) from Brian Biggar to AML & Business Risk. Changed Office Dir./Bus. Head/GMTH/SMTH Approver to Brian M. Biggar. Changed Status from 3. Ready for Office Dir Approval/SMTH to 4. Ready for AML & Bus. Risk Approval. 7/17/2013 2:10 PM User Paul Morris Action Changed Case Owner from Paul Morris to Brian Biggar. 7/17/2013 2:10 PM User Paul Morris Action Changed Primary Officer/RM Approver to Paul Morris. Changed Status from 2. Ready for Primary Officer Approval to 3. Ready for Office Dir Approval/SMTH. 7/17/2013 2:09 PM User Amanda Kirby Action Changed Case Owner from Amanda Kirby to Paul Morris. 7/17/2013 2:06 PM User Amanda Kirby Action Changed Status from 1. In Progress to 2. Ready for Primary Officer Approval. 5/28/2013 10:27 AM User Amanda Kirby Action Created. Copyright 0 2000-2015 salesforce.com, inc. All rights reserved. EFTA01409529 https://dbforcepb.my.salesforce.com/5006000000Qah5L/p?retURL=/- 5006000000Qah5LA... 8/28/2015 EFTA01409530