EFTA Document EFTA01299334

From: 2101SIBICIISIEL To: Subject RE: PEP Escaletionjeffrey E. Epstein Date: Friday, October 19, 2018 5:15:52 PM Attadiments: tifiNg043..P02 Hi Gwen: I agree with your assessment that Mr. Epstein should be treated as a RCA. Hence, all clients where he is UBO or has a significant controlling role should be automatically risk rated "High" Regards, Janice P. Franklin Janice Franklin, CAMS, CFSA, CFIRS Vice President I ASK Compliance Officer Deutsche Bank Americas Regulation, Compliance & Ardi-Financial Crime 60 Wall Street. 10005-2836 New York, NY, USA Tel. Emai From: Gwen Hill Sent: Friday, October 19, 2018 2:30 PM To: Janice Franklin <[email protected]> Subject: RE: PEP Escalation_Jeffrey E. Epstein Hi Janice, The purpose of this email is to address the PEP status of Jeffery E. Epstein, an existing Wealth Management client through the Southern Financial Relationship. Although the PEP status was factored into the prior risk calculator, the client was never formally escalated as a PEP. It has been reported in the media that Mr. Epstein has maintained a close relationship with Prince Andrew, Duke of York and member of the British Royal Family and former US President, Bill Clinton. Several media sources have reported Mr. Clinton and Prince Andrew have used Mr. Epstein's private passenger jet "Lolita Express" on numerous occasions. The relationship is currently "High" Risk. Although Mr. Epstein was treated as an honorary PEP in the past, he was never formally escalated as a PEP. BLAFC-WM reached out to the business and they SDNY_GM_00065252 CONFIDENTIAL - PURSUANT TO FED. R.QQN(F IDENTIAL DB-SONY-0028077 EFTA_00175752 EFTA01299334 agreed he should remain a PEP. Please let us know if you agree that Mr. Epstein should be treated as a Relative or Close Associate (RCA) of a PEP due to his connections to Prince Andrew and Bill Clinton. Kind regards, Gwen/ H ill/ Gwen Hill AVP I AML Compliance Officer DS USA Core Corporation Regulation. Compliance and Anti-Financial Crime Anti-Financial Crime 5201 Gate PINIONS . 2nd Floor, 32256 Jacksonville. USA Tel. Email SDNY_GM_00065253 CONFIDENTIAL - PURSUANT TO FED. R.CON(F IDENTIAL DB-SDNY-0028078 EFTA_00 175753 EFTA01299335