EFTA Document EFTA01299337

From: Gwen MB To: PWMUS AMLRYC Cc: Gwen Hill Subject: CLEARED: PEP Escalation_Jeffrey E. Epstein Date: Monday, October 22, 2018 8:53:18 AM Attachments: imaoe003,202 From: Janice Franklin Sent: Friday, October 19, 2018 5:16 PM To: Gwen Hill Subject: RE: PEP Escalation_Jeffrey E. Epstein 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 AML Compliance Officer Deutsche Bank Americas Regulation. Compliance 8 Anti-Financial Crime 60 Wall Street, 10005-2836 New York, NY, USA From: Gwen Hill Sent: Friday, October 19, 2018 2:30 PM To: Janice Franklin <janice.franklinPdb.com> 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. SDNY_GM_00065265 CONFIDENTIAL - PURSUANT TO FED. R.ctQN(F IDENTIAL DB-SDNY-0028090 EFTA_00 I 75765 EFTA01299337 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 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, Gwent, Hal. Gwen Hill AVP I AML Compliance Officer DB USA Core Corporation Regulation. Compliance and Anti-Financial Crime Anti-Financial Crime loor, 32256 Jacksonville, USA SDNY_GM_00065266 CONFIDENTIAL - PURSUANT TO FED. R.ctON(F IDENTIAL DB-SDNY-0028091 EFTA_(( )175766 EFTA01299338