Case File
efta-01409570DOJ Data Set 10OtherEFTA01409570
Date
Unknown
Source
DOJ Data Set 10
Reference
efta-01409570
Pages
6
Persons
0
Integrity
Extracted Text (OCR)
EFTA DisclosureText extracted via OCR from the original document. May contain errors from the scanning process.
Subject: RE: Epstein account openin [I]
From: Daniel Sabba
Date: Mon, 01 Feb 2016 15:05:24 -0500
To: Todd Stevens <a>
The issue is that JE was listed as president of Gratitude America Ltd in the
entity's original articles of incorporation. Additionally, JE was listed as
the source of funds in the initial KYC done by Paul's team.
When Ari reached out to Middle Office, they looked at the KYC and flagged
the request as "high risk" and asked us to get AML approval. As you recall,
we already went to AML (Wayne Salit) to ask whether the account opening
could be done. Wayne was the one who referred us to RRC.
When we went to the RRC, they requested an external updated Enhanced Due
Diligence Report. The entire back and forth over the past week is on the
request for this report, which is under Paul's review for sign-off.
In summary, first, the KYC does not reflect this is a separate relationship.
Second, given the post-facto nature of the changes in the article of
incorporation, I think AML/RRC are very likely to still require the due
diligence report.
From: Todd Stevens
Sent: Friday, January 29, 2016 4:59 PM
To: Daniel Sabba
Subject: Fwd: Epstein account opening [I]
Thoughts? What is JE's role here?
Begin forwarded message:
From: Paul Morris a
Date: January 29, 2016 at 2:03:59 PM EST
To: Todd Stevens a
Subject: FW: Epstein account opening [I]
EFTA01409570
Classification: For internal use only
Todd, so why are we doing this? This should be separate relationship
Paul Morris
Managing Director
Deutsche Bank Private Bank
From: Ariane Dwyer
Sent: Friday, January 29, 2016 1:59 PM
To: Paul Morris; Daniel Sabba
Cc: Todd Stevens; Vahe Stepanian; Mark Frankel
Subject: RE: Epstein account opening [I]
Hi Paul,
That is correct.
Best,
Ari
From: Paul Morris
Sent: Friday, January 29, 2016 1:54 PM
To: Ariane Dwyer; Daniel Sabba
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
Subject: RE: Epstein account opening [I]
EFTA01409571
Classification: For internal use only
So Ari we confirmed that JE is not an officer and not source of funding of
this foundation correct? I'll look at form you sent over now. thx
From: Daniel Sabba
Sent: Tuesday, January 26, 2016 1:18 PM
To: Paul Morris
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
Subject: RE: Epstein account opening [I]
Paul, thank you for your note. We just double checked and Gratitude
America's formation docs lists JE as president and the entity's KYC lists JE
as source of funds. Please complete the request form whenever possible — Ari
can help. Thank you, Daniel
From: Paul Morris
Sent: Tuesday, January 26, 2016 12:59 PM
To: Daniel Sabba
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
Subject: RE: Epstein account opening [I]
Daniel, isn't Gratitude America a 501-3c? Epstein is not an officer of this
and don't think was funded with his $. I'll be back in NY Thursday. If we
still need to do the external due diligence on this one let me know and I
can do over the phone with Ari and you can submit. Thanks
Original Message
From: Daniel Sabba
Sent: Monday, January 25, 2016 04:40 PM Eastern Standard Time
To: Daniel Sabba; Paul Morris
EFTA01409572
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
Subject: RE: Epstein account opening [I]
Hi Paul — I hope all is well. We wanted to circle back on this form. Thank
you, Daniel
From: Daniel Sabba
Sent: Thursday, January 21, 2016 3:37 PM
To: Paul Morris
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
Subject: RE: Epstein account opening [I]
Paul — I am CCing Mark Frankel, who is the best person to answer any
questions on this document, as it was produced by his division.
Mark, can you please connect with Paul Morris with regards to his questions?
Best regards,
Daniel
From: Paul Morris
Sent: Thursday, January 21, 2016 3:13 PM
To: Daniel Sabba
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer
Subject: RE: Epstein account opening [I]
Classification: For internal use only
Daniel, can you or Todd please call me to explain this document? Thanks
Paul Morris
EFTA01409573
Managing Director
Deutsche Bank Private Bank
From: Daniel Sabba
Sent: Thursday, January 21, 2016 11:03 AM
To: Paul Morris
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer
Subject: Epstein account opening
Paul,
Per our conversation, the reputational risk committee has requested an
external due diligence report as a step towards the approval for opening an
account for Gratitude America. This report takes about eight business days
to be completed, but we need you to please complete the attached request
form to get it started.
The committee has informed us DB personnel cannot disclose to the client
this matter is being evaluated for reputation matters. They have asked that,
when inquired, we communicate to the client "we are in the process of
internal due diligence to review the opening of this account, as it is done
with all new accounts".
Ari can help fill in any information you need in this form.
Thank you in advance,
Daniel
EFTA01409574
Daniel Sabba
Deutsche Bank Securities Inc.
Email
EFTA01409575
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