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efta-efta01282185DOJ Data Set 10Correspondence

EFTA Document EFTA01282185

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EFTA Disclosure
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KYC l'rint Pagel of 10 DB PWM GLOBAL KYC/NCA: PART A KYC Case * : 01898372 One sheet must be established per relationship- list all accounts included in the relationshi 1. Relationship Details Relationship Name: SOUTHERN FINANCIAL RELATIONSHIP:00000483290 Boddng Center: New York Relationship Manager: Stevan Oldridd O New PPM Reladonship O eating Meal Relationship Relationship to PM: If caisdrg, please indicate axe when the !deanship oasts, provide reason for new profile and attach old wade: Initial funding must take place by 02/13/2018 In order to pachase assets for the trust 0 Gent Referral O RM Prospect O Intermediary/FIN O Other Source (OS, etc) How Was the Clangs) Introduced? How bang has the RM personally known the client? Please provide details (e.g. name of referral son, new many years RM person.* has known dent, etc.): Jeffrey Epstein reamed out to Stew CliclAdd x12/02/2018 to open a new deposit account for Ns annuity trust. Intel fielding must take state by 02/13/2018 in order to purchase assets for the trust Does Deutsche Earle pay a rehear:slat or singer O yes I IA No compensation to a third party for the introduction of this relationshp? (If Ve5 cksate) List di existing and new accounts Invoked in this relatbnalp Legal Enay AccouM(s) Account Name 1 minter opening Date (Intended/actual) 1 D The 2017 Caterpitar Trust . Deposit 2/13/2018 Who is the primary muted person a the RH? (Note: TVs person needs to nave soatory right and/or Information right for the accounts.): , Preferred method 01 contact (indicate phone ro., fax no., email address, etc.): Status : 6. Approved SDNY_GM_00037476 CONFIDENTIAL - PURSUANT TO FED. R. Ce I ON FIDENTIAL DB-SONY-0000300 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... 7/11/2019 EFTA_00148088 EFTA01282185 KYC Print Page 2 of 10 One sheet must be established for each account to be opened 2. Account Ownership Summary Account Name: The 2017 Caterpillar Trust - Deposit Acct. Minter tifoludablet. Account Manager: stenett oldfield What is the purpose of the account (e.g. prmfdlo management, advisory aocouit, custody senaces, long-term Investment. paymentlesPerde amount)? the Purpose of this account k to hold the member Interest in IGO Company LLC Indicate from where the assets are expected to arrive? GO Group: Same Stoking Center (indicate account number): 3526%91 O GO Group: Other Booting Center (indicate GO location and account details): O Other Ins/Motion - (lndkate name & location): O Physical Deposits (spedfy cash, securities, cheques....): What is the expected size and frequency of regular inflows and outflows for the account (Indicate estimated number and yolune per month)?: less than 2 dstrituticns on an annual basis between $0 and $100k What is the expected volume of assets and currency for the account approx. 90 days alter opening? 1 300000 I Currency I usd what is the expected volume of assets and currency for the account approx. one year after opening? 1300000 I Currency I usd Does/will the client have Assets Under Management (AuM) within DC under arr. 3M? OYes 0 No Please list 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 relabonshp of the party to this account (> 1 can be selected). I none of the check bco2s appty, describe the palls elation to the account in the "Other column. • Always describe the relation hp between the parties I the last column. • Please WI down to the ubmatejundedying Benefidal Owner(s) egS Enthral DescrOUNI Source of Wealth equired Parties related to this account AccormtP1C Holder Omer/Trust SetUor of / Founder of Foundation Ultimate Benefidelor Owner SignalogyLimrtedFinandal Full POA POA IntermediarySharenokleriztepresentaUye :FIM) Significant K>=25%) hbn.PiC entity (indicate ownership %) _egal Granter/Settlorfouiding Dona Other (please describe other roles and/or indicate relationship between parties) 1 El 0 The 2°17 Caterpillar Trust 21 O O O O O O O O O 2 O 2 'emel t Epstein O O 2 O O O O O O O Beneficiary:Grantor and Benefidary of The 2017 cater oar Trust.;Grantor of The 2013 Butterfly Trust; 3 O O "Kei Daphne l: OO O EJ O O O O O Trustee:;Uustee; 4 O O .OOO O Ei O O O O O trustee; Trustee:: SDNY_GM_00037477 CONFIDENTIAL - PURSUANT TO FED. R. t I ONFIDENTIAL DB-SONY-0000301 https://dbforcepb.my.salesforce.com/servlet/servlet.lntegration?lid=01N30000000D9Di&e... 7/11/2019 EFTA_00148089 EFTA01282186 KYC l'rint Page 3 of 10 One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa 3A. Individual Details (Mg all panes) Indlviduars Name: Jeffrey E. Epsten - Date d Birth: 1120//953 Country of Residence: USVI Country of Otizenship: USA Address of primary residence: Utte Sant James Saint Thomas 00802 United States Has client resided outside d Ns/her country of nationalty for 5 years or more? No ID yes IS Profession/Oxupation: Self Empolyed Tax ID / SSN: Cur-rent Employer: Southern Trust Company LLC PositkrVTIVORank: President Address of employer: 6100 Red Hook Quarter B3 St. Thomas United States 00802 Does the person work as senior executive of a DB-recognized regulated entity in the financial ndustry? or an edgy aged on a DB-recognised exchange? (Not applicable for operating entities • Ts Ea No Is the indteidual a Politically Exposed Person (PEP)7(1Y Yet deznbe) connection with Prince Andreve and 611 Clinton 2 yes O No To the best of you knowledge. Is the Vidividual !Sated to an employee of the DB group?&Fandy or Frieruthip, ciesothe) O Family O Men:Islip El None To the best of your knowledge, is the IndNiduS party to a non-banking relationship wth Deutsche Bank (e.g., external legal counsel, client referral sows, supplierof goods or seNices)?(if YesYea-etc ) o yes 2 No If applicable, Indicate which bank officers have nice the person: Indicate where and when the client meeting(s) took place: Bank Officer Names) Bank Of Client Private Domicile: Crient Place of Business: Other Location (specify): Date: O O O O O O O O O O Wealth Details for this Individual are not fled in, because they are the same as for the following person: 38. Wealth Details (Only for parties requiring soLece of wealth description as indicated in Section 2) Nature of the Individual's Business: Prhete investments Winery Country of source of weSM/source d Funds? Primary industry of solace of WeaUVSource at Funds? Summarize Source of Wealth: g Buenas Owner O Salary/Earnings 2 Investment O Inheritance/Gifts O Other: Futile Describe Source of Wealth /Detail the tistoey of wealth for each of the scums: (e.g. For trusts, how did settler acntrulate wealth? For inheritance, how Si fan* accumulate wealth?For business owners, how long in business, how many employers, level of prontaNlity? Indicate type of business, countries of major activities, important business partners.) Jeffrey Edema' Epstein (born January 20, 1953) is an Amerkan (Mender and **game sex offender n the Wiled States. He worked at Bear Steams early n his career and then famed his own fkm, 1. Epstein & Co. In 2008, Epstein was Convicted of soboting an underage gin for prostitution, fa which he served 13 months in prison. He Ivies in the US Virgin Islands. EpsteM taught catulus and physics at the Dalton School in Manhattan from 1973 to 1975. Arnong his students was a son of Alan C. Greenberg, chairman of Bear Stearns. In 1976, Fasten started work as an options trader at Bear Stearns where he worked in the special products division, advising Ngh-net-worth clients on tax strategies. Proving successful in cis financial career, in 1980 Epsten became a partner at Bear Stearns. In 1982, Epstein founded his own financial management firm, J. Epsten & Co., managing the assets d dents with more than $1 billion in net worth. In 1987, Leslie Wexner, founder and chairman d Ohio-based The Limited chain of women's clothing stores, became a wed-knovm client. Werner acquired Abercrombie & Etch the felbning year. In 1992 he converts a private school on the Upper East sde Into an enormous residence. Epstein later bought that property, in the wealthiest part of Manhattan. In 1996, Epstein changed the named his firm to the sandal Trust Company and, for tax advantages, based it on the sand oft Thomas In the US Virgin Islands. In 2003, Epstein CO to acquire New York magazine. Other ladders were advertising executive Denny Deutsch, investor Nelson Pet, media mogul and publisher Mortimer Zuckerman, who had the New York Daly News, and film producer Harvey Weinstein. They were ultimately outtid by Bruce Wasserstein, a longtime Wall Street Investor, who pad $55 million. In 2004, Epstein and Zu:kerman committed up to $25 mson to finals Radar a celebrity and pop cuture magazine fended by Meer Roshan. Epsten and Zuckerman were equal partners in the vette. Roshan, as its edict-in-chief, retained a grail ormershp stake. Po:sentry, Mr. Epstein founded Southern Trust Company Inc, a private consulting company that invests the assets of their clients and gets their revenue from the return of these Investments. Southern Trust invests in different pa-tit:dos catered to their dents and makes their revenue based on the returns and the fees associated with managing their client's assets. CONFIDENTIAL- PURSUANT TO FED. R. Ce I ONFIDENTIAL h tps://dbforcepb.my.salesforce.com/servlet/servletintegration?lid=01N30000000D9Di&e... 7/11/2019 EFTA_00148090 SDNY_GM_00037478 DB-SDNY-0000302 EFTA01282187 KYC Print Page 4 of 10 Estimated Annual Imome($): 10,00%000.00 Estimated amount d investatfe assets(S): S50 MM - 100 Mel Estimated Net Wath(S): $500 MM + Amount of assets plains to invest with PWM(S): Other Known Financial Institubcos: Institution: Country: Est. Assets Under Mgt: Institution: Country: Est. Assets Under Mgt: Institution: Country: Est. Assets Under Mgt: Please in&ate the family sAuaUdi of the incfMdual (marital stabs, otter family members, etc.): SDNY_GM_00037479 CONFIDENTIAL - PURSUANT TO FED. R. Ce I ON FIDENTIAL DB-SONY-0000303 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... 7/11/2019 EFTA_00148091 EFTA01282188 KYC l'rint Page 5 of 10 CONFIDENTIAL - PURSUANT TO FED. R. Ce I ON FIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servletintegration?lid=01N30000000D9Di&e... One sheet must be established for EACH INDIVIDUAL PARTY In Section 2. Account Ownership Summa 3A. Individual Details (for all pubes) Individual's Name: Wallace, Daohre - Date of Birth: 6/19(1967 Country of Residence: USW Country of Citizenship: USVI Address of primary residence: Has client resided outside d Ns/her country of nationally for 5 years or more? No Oyes 5 ProfessionfOxupation: Finance Tax ID / SSN: Current Employe: Southern Trust Company Inc Position/Title/Rank: controller Address of employer: 6100 Red Hock Quarter St Thomas United States 03802 Does the person work as senior executive of a DB-recognized regulated entity in the financial ndustry? Of an entity aged on a DB-recognised exchange? (Not applicable for operating entities 0YaIONo I5 the indhidual a Politically Exposed Person (PEP)7(d der*/ ❑Ores @to To the best of yow knowledge. Is the Indhidual related to an employee of the DB group?(eNswair or Friendship, tome) O Family O Friendship 2 Nene To the best of your knowledge, is the individual party to a non-baniong tattoo() wth Deutsche Bank (e.g., external legal counsel, client referral sowce, Replier of goods or unices)?(ff Yesdesatie) Oyes 171 No If appicable, indicate which bank officers Nye met the person: Indicate where and when the client meeting(5) took place: Bank Officer Names) Bank office: Client Private [amble: ent Raced C Other Business: Othe Location (specify): Date: O O O O O O O O O O wealth Details for this individual are not Med In, because they are the same as for the following person: 3B. Wealth Details (Only for parties requiring sane of wealth description as Indicated in SectIon 2) Nature of the Individual's Business: Winery Country of source of wealdVsource of Funds? or/ran' industry of source of Wean/Source of Funds? Summarize Source of Wealth: O Maness Owner O Salary/Earrings O investment O inmotance/Girts O Other: Further Describe Source of wealth meta the hstory of wealth for each of the sources: (e.g. For bras, how did settle accenulate wealth? For Inheritance, how did fan* accumulate wealth?For business owners, how long In engine's, how many employees, level of prcntability? Indicate type of business, countries of major activities, important business panes.) Estimated Annual Ireame($): Estimated amount of (v table assets(5): Estimated Net Werh(5): Amount of assets panned to invest with PW74(5): Other Known Financial Institutions: insbtLieon: Country: Est. MSS Under Mgt: inotution: Country: Est. ASSerS Under Mgt: IndefurdOn: Country: Est. ASSere Under Mgt: Please inch:ate the family situate, of the iranidual (marital stabs, otter family members, etc.): SDNY_GM_000374S0 DB-SONY-0000304 7/11/2019 EFTA 00148092 EFTA01282189 KYC Print Page 6 of 10 CONFIDENTIAL - PURSUANT TO FED. R. Ce I ON FIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=0IN30000000D9Di&e... One sheet must be established for EACH INDIVIDUAL PARTY In Section 2. Account Ownership Summa 3A. Individual Detaes (for all parties) Indlviduars Name: Groff, Date of Birth: 10//41966 Country of Residence: USA Country of Citizenship: USA Address of primary residence: Has client resided outside of Ns/her wintry of nationally for 5 years or more? Dyes into Profession/Occupation: Attorney Tax ID / SSN: Current Employer: Darren K Indyke PLLC PosIticrVTIUWRank: Attorney Address of empOyer: 575 Lexington Avenue 4th FL new work NY United States 10022 Does the person work as senior executive of a DB-recognized regulated entity In the financial ndustry? or an entity aged on a DB-recognised exchange? (Not boob:sob* for operating entities • Ws 0 No Is the indlodual a Politically Exposed Person (FEP)?(if Yes, otexigu) ates 2 No To the best of yow knowledge. Is the IndNidual related to an employee of the DB group?0f Pam* Or Friendship, desothe) O Family O Friendship 2 None To the best of your knowle6ge, Is the individual party to a non-banking relationship wth Deutsche Bank (e.g., external legal counsel, client referral soiree, suppler of goads or sinAces)?07 Yesdesentre) ales 171No If appleable, Indicate which bank officers have met the person: Indicate where and when the client meeting(%) book Bank Officer Names) Bank Office: Other Client Private Donnie: Crent Place of Business: Location (specify): Date: O O O O O O O O O O Wealth Details for this IndiVdual are not filed In, because they are the same as for the following person: 3B. Wealth Details (Only for parties requiring scarce of wealth description as indicated in Section 2) Nature of the Individual's Business: Primary Country of source of wealth/source of Funds? Primary industry of solace of Weatifigourced Funds? Summartze Source of Wealth: O Baseless Owner O Salary/Earnings O Investment O Inheritance/Gifts O Other: Father Describe Source of Wealth /Derail the Nstory of wealth for each of the sources: (e.g. For trusts, how did settler ace...notate wealth? For Inheritance, how Ofd family annulate wealth?For business owners, how long In business, how many employees, level of praitability? Indicate type of business, countries of major activities, apatant business partners.) Estimated Annual Inoame($): Estimated amount of investable asses(5): Estimated Net Worth(S): Amount of assets plumed to invest with PW74(S): Other Known Financial Institutions: InsritUdon: Country: Est. Assets Under Mgt: InsritUdon: Country: Est. Assets Under Mgt: Insbtrldon: Country: Est. Assets Under Mgt: Please Indicate the family situatron of the incfrAdual (marital stabs, other family members, etc.): SDNY_GM_00037451 DB-SONY-0000305 7/11/2019 EFTA_00148093 EFTA01282190 KYC l'rint Page 7 of 10 CONFIDENTIAL - PURSUANT TO FED. R. IA I ON FIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servletintegration?lid=01N30000000D9Di&e... One sheet must be established for EACH LEGAL ENTITY In Section 2. Account Summit 3C. Legal Entity Details (Foe al Legal Entities) Legal Entity Name: The 2017 Caterplar Trust - 00000S7S9E0 Type of Entity: • FoLodatron/Associatlon HI Trust O Company O Estate O Noose of Eray: g Private Investment O Flilianthr0PIC/Cteritatte O Commercial Partnershp 'Pape of Entity Other (specify): Purpose el Entity Cther (specVy): Country a occeporationffegistratron: Virgo Islares, U.S. Date of Ina:tamale)/ registration: 43/2017 Volcker Status: Determination Required Vokker Flag: No Address (ay, street, post cede): 6100 Red Nook Quarter 83, St Thomas 00802 UNted States U.S. TIN/EIN: PtcMde a description a the entity's organizational structure, is ownership structire and Its Top Management. Fa busts/foureations, inclikle information about reyccaNlity,settlor and tenelidaries,etc: this is a grantor retained annuty trust that holds membership interest in IGO Company U.C. This trust will terminate two years from the date of initial funding and annual annuity distributions will be paid to the grantor only. Upon termination, the membershb interest wall then transfer to the 2013 Butterfly Trust. Grantor: Jef Sftri ...: Trustee: and Daphne Wallace Beneficiaries: Jeffrey Epsten and The 2013 Butterfly Trust (Loco termination of trust) Please indkate how ownership of the legal entity is reflected: trust agreement O Spada attention: Bearer Shares - Indicate where shares we custodied: Describe the chain flan the direct owner of the entity to the ultimate benefiCial owner (loot Me same pawns) Grantor: Jeffrey Epstein Trustee: and Daphne Wallace Beneficiaries: Jeffrey Epstein and The 2013 Butterfly Trust (upco termination of Oust) To the test of your knovfledge, is the entity party to a non-banking reationship veith Deutsche Bank I (e.g. external legal mune, client retell source, supplier of goods or services)?: Yes O NO Describe Nature of Entity's Primary Business and Investment Activities Nature of the tipsiness: This Is a grantor retained annuity trust that holds rnembersNp interest in IGO Company U.C. Countries where busines k transacted: usa Number of employees: 0 30. Wealth Profile (Only for parties requiring souse of wealth description as indicated in Sectbn 2) Primary Country of source of wealth/source e Funds? Primary industry of saute of Wealth/Source of Funds? Picnide Evidence of Corporate Assets (e.g. balance sheet a eq tralent summay or assesillabilltres): The source of wealth for this trust derhes from Jeffrey Epstein. Please revert to his source of wealth for more detait.. Estimated gross receipts p.a.($): 1,000,000.00 Estimated net plait p.a. (5): 1,000,000.00 Estimated investable assets ($): SI MM - 2 MM Potential AMOUrbt to be invested with MUM (5): 1,000,000.00 Other Know', Financial Institutions: laser/Jon: Country: Est. Assets Under Mgt: InstturJon: Country: Est. Assets Under Mgt: InstturJon: Country: Bt. Assets Under Mgt: SDNY_GM_00037482 DB-SONY-000030S 7/11/2019 EFTA_00148094 EFTA01282191 KYC Print Page 8 of 10 CONFIDENTIAL - PURSUANT TO FED. R. IA I ON FIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... DB PWM GLOBAL KYC/NCA: US/LatAm/1M1 PART B Ftelatienshp Name SOUTHERN FINANCIAL RELATIONSHIP Risk Rating Laments: Boling Center 0 NY O NY/Offshore O offshore V skr.bderate OHO RNA ]Teensuri thong (Compliance Signature) O DB Employee Doe Managed PIC O DB Is Trustee/Co-Trustee O Bearer Shares 4. Attachments A. Type et Photo ID Frowided @ Drivers License Passport O National/State ID O Other B. Checklist of names (indiAduals and/or entitles) that were submitted fa database seethes Is attached Oyes O No C. Please inlcate the results of the database searches pertained FtDC searches complete ®Yes O No negative results found O Yes 12 No PCR checks complete ®Yes O No negative results found O Yes 0 No OFAC checks complete 10 Yes O No negative names found O Yes OM BIS searches complete (Lees/Nees, Factka, Reuters, Dow Jones, DAB) ®Yes El No negative names found O yes @No Denial Orders checks complete ®Yes O No negative !1st found O yes El No Mailindare-Hubeell searched (LawyersfLaw Firms only) Oyes @No negative results Found Oyes O No D. Please summarize any negate.* results from the database searches indicated above: E. To the best of your kneAtedge, has the diet ever been convicted of a criminal offense? ®Yes ONo E To the best of your knairtedge, has the customer ever been invoNed in any past ItigaUcti against Deutsche Bank AG or any of its subtleties or is the customer [Neatening litigation against Deutsche 5 No Bank AG its Sot:hares? Yes or or any of (If Yes prey.* deals below onfl contact Quaky Mgt aatiroWnW the ReSeditay Control &OOP and notify Compliance immeStely) G. Does the dent or related party have any Maids a other association f interacUens wthin COUrarleS or • Yes 0 No mama sanctioned by the Dmce of Fordgn Assets Control (OFAC)? N. Does the cleat or related party have any Enatial or other association/ interactions within high risk countries? O Yes @No I. Corporate Documettarien Attached (Legal Entities 000 ®Yes O No O Notary/caw J. Undisclosed Prinlpal Form Complete (Intermediaries Only) • Yes • No 2 Not eopecaNe K. If Leis/Neils Search Resift, Corporate momentsor Other Supporting Documetada) is net in English, please provide an Enoch summary of the Toffee/octets of the non-Enosh Documentation: L. Special RI Factors Does the account have Nears to Special Risk Countries? Ores 0 No Is the a:cowit StrLICRIM initially complex? Oyes RIND is there any indicate, the client se up a ron operating company expressly for O yes 2 No the purpose of transferring shares to [NM pates? Dyes Is thee any indicatbn this could be a prohibited business relationship? 12 No Are the bearer shares deviled subject to acceptable controls? Dyes 121reo SDNY_GM_00037453 DB-SONY-0000307 7/11/2019 EFTA_00148095 EFTA01282192 KY(' Print Page 9 of 10 M. Case Comments Created By Date Comments Your ,Ur CI i., ', 4 3/18/118 10:52 AM The client Trust is regstened in US VI, not USA. Matthew-3 Purcell 2/13/118 11:13 AM TNs Kit senes as a Ngh risk review for the new client The 2017 Caterpilar Trust (referred as accountholder') - Below are the reasons why we are comfortable with approving this KYC: • Intl:gyration and supporting documents recryAred by our NIL Poky were provided and reviewed; and as a resit we "rave an understanding of the struchre of the accountholders, thee propose, the purpose of the accounts and expected 3ansaction actNity. • Thee are a few risk factors associated with the accountholder- SOW: The UBO (Jeffrey Epstein) Is the 'molder of Southern Trust Company Inc. Witch manages clients assets. SOW verification was obtained. Negative Meda & PEP: There is some negative media against Mr Epstein and he is also maintains a dose Satonship wth EA Clinton and Prince Mdrew. Please see rid( calculator for more information. Appropriate approval vas obtained. • Our refew did not identify any red flags and thus there was no need to escalate the case further. • We performed due dibgence searches on all parties and did not find the names searched to be on any sanctions lists Cynthia Rodriguez 2/8/118 10:59 AM Please Note: The 2013 Butterfly trust is listed as a beneficiary only when the 2017 Caterpilar Trust terminates. Since this benefbary does not receive the annual annuity payments, ewes not added as a party. However, there attached the trust agreement and list of beneficiaries for this trust as support ONSHORE APPROVALS Client Facing Professional (CFP): stewart °Weld ;Sgnatue) stewart (Wed 2/8/2018 Office Deector/Business Head: Mdrew F Gallivan (Signature) Mdrew F Gallivan 2/8/2018 Regional Office Director: (Signature) AML Business Risk: (Signature) AML Compliance: Matthew-) Purcell Yoonsun Chung (Sgnature) Matthew-) Purcell Yoonsun Cliung 2/13/2018 2/13/2018 tATAm / INTERNATIONAL APPROVALS Client Facing Professional (CFP): (Signature) Account Manager: (Striatum) Global Market Team Head (GMTH)/Sub- Market Team Head (SMTH): (Signature) AML Business Risk: (Sgriature) AML Compliance: (Signaturel PRIVATE WEALTH MANAGEMENT POLICY STATEMENT: Deutsche Bank Private Wealth Management (PWM) worldwide is committed to professionally serve the interests of its clients. To do so, Client Facing Professionals1(1) (CFP's) should establish and maintain business relationships only with persons who swish, 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 inception of a relationship and on an ongoing basis. SDNY_GM_00037484 CONFIDENTIAL- PURSUANT TO FED. R. IA I ON FIDENTIAL DB-SONY-0000308 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... 7/11/2019 EFTA_00148096 EFTA01282193 KYC Print Page 10 of 10 DECLARATION FOR ALL SIGNERS OF THIS FORM: To the best of my knowledge and belief the above information is correct and up to date. I confirm that I have no suspicions relating to the money laundering or unethical activities on the part of the client(s) and that I 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's) include: Relationship Managers, Wealth Advisors, Product Officers. Brokers. Client Managers, etc. Deutsche Bank Amerkas New York SDNY_GM_00037485 CONFIDENTIAL- PURSUANT TO FED. R. IA I ON FIDENTIAL DB-SDNY-0000309 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... 7/11/2019 EFTA_00148097 EFTA01282194

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