EFTA Document EFTA01371142

rdc DB12000P - Deutsche Bank Private Bank Alert Batch Date: 6/15/2017 Alert Date: 6/15/2017 Added to Monitoring: 06/15/2017 Organization: Southern Financial LLC Address: Country VIRGIN ISLANDS, U.S. Tracking ID: KYC 1790655 Reporting ID: Alerted Entity # 2 of 4 Event: • SEC - SEC Violations (Insider Trading, Securities Fraud) / ACT - Disciplinary. Regulatory Action, 04/29/2008 The SEC announced that the USDC for the Middle District of North Carolina entered final judgments against defendants Elfindepan, S.A., Strategic Asset Funds, S.A., and Southern Financial Group for their roles in a high-yield investment scheme. Elfindepan, a defunct Costa Rican company. SAF, a defunct Panamanian company, and SFG, a de facto trust, were controlled by defendant Tracy Dunlap. The Commission alleging that Elfindepan, SFG, SAF, and others defrauded investors nationwide of approximately $30 million in connection with a high-yield investment scheme involving the unregistered offer and sale of Securities of Elfindepan, a purported Costa Rican financial company; alleges that Elfindepan made numerous materially false and misleading statements including promising investors that their investments were secure and would yield returns of as much as 40% to 50% per month., 04/2972008, SEC Litigation Releases - 2008 • SEC - SEC Violations (Insider Trading, Securities Fraud) / ACT - Disciplinary, Regulatory Action, 09/12/2002 The Court in this case adjudged defendants Elfindepan, Southern Financial Group, and Tracy Calvin Dunlap, Jr., to be in contempt of court and ordered Dunlap incarcerated based on their refusal to obey court orders requiring them to produce documents and account for and repatriate investor funds., 09/12/2002, SEC Litigation Releases - 2002 • SEC - SEC Violations (Insider Trading, Securities Fraud) / ACT - Disciplinary, Regulatory Action, 04726/2001 On March 15, 2001. the U.S. District Court for the Middle District of North Carolina adjudged Elfindepan, S.A.. Southern Financial Group and Tracy Calvin Dunlap. Jr. to be in civil contempt of court based on their refusal to obey court orders requiring them to produce documents, and account for and repatriate investor funds. related to their allegedly fraudulent investment schemes. They refused to comply as ordered based on their assertion of Dunlap's personal Fifth Amendment privilege against self-incrimination.. 04/26/2001. SEC Litigation Releases - 2001 • SEC - SEC Violations (Insider Trading, Securities Fraud) I ACT - Disciplinary, Regulatory Action, 08/10/2000 The SEC filed a fraud case in the United States District Court for the Middle District of North Carolina against Elfindepan, S.A., Southern Financial Group, Tracy Calvin Dunlap, Jr. and Barry Lowe. The SEC complaint alleges that, the defendants defrauded investors nationwide in an apparent Ponzi or pyramid scheme in connection with the unregistered offer and sale of the securities of Elfindepan, alleges that in connection with these offerings, defendants knowingly and recklessly made, and caused others to make, numerous materially false and misleading statements to investors, defendants promised investors highly favorable returns on investments, without any reasonable basis for such claims, and falsely stated that the investments were secure, including false claims that Elfindepan investments were associated with the International Monetary Fund and the World Bank and also alleges that defendants knowingly or recklessly failed to disclose certain material facts to investors regarding Elfindepan., 08/10/2000, SEC Litigation Releases - 2000 Risk Priority: Critical Alert ID: 9476247.11602637.65374193 Alert Notes Notes: Southern Financial Group was charged with securities fraud . Calsotent uith the terms and cc...aeons d your RDC Sutocnber Agreement the rricernaban contained n ths document is for alert purposes only and not to be used la purposes of deteernrang an eclrecluafs avidly la any aerie or any Atha FCRA permissible purposes User further agrees to hold such matenal and 'Moms/eon in totes! C011idOnCe. not tOrnefrguse thereof other than fir authctged pLifFaBOS. to Side it only to employees revering such warcerrohen, and not to release a disclose n to any other party The Alert Somata, contained in the document nay or my not pertain to the off On Oual a 'May referenced et your Elquily. Page 5 0l 9 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0064354 CONFIDENTIAL SDNY_GM_00210538 EFTA01371142