EFTA Document EFTA01372918

7/15/2019 KYC Print M. Case Comments Created By Date Comments Cynthia Rodriguez 9/6/117 12:05 AM recent research and google searches for Erika Kelerhals can be found in approved case 01790655. Cynthia Rodriguez 9/6/117 12:09 AM ID for Erika Kellerhals can be found in approved case 01344537 KshrtO Golani 916/117 3:22 PM This KYC serves as a high risk update for the below listed clients (together "accountholders") - 1. The Haze Trust 2. Butterfly Trust 3. The 2007 Jeffrey E. Epstein Insurance Trust 43 Below are the reasons why we are comfortable with approving this KYC: • Information and supporting document required by our AML Policy were provided and reviewed; and as a result, we have an understanding of the structure of the accountholders, their purpose, the purpose of the accounts and expected transaction activity. • There are a few risk factors associated with the accountholders - SOW: The U80 (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages clients assets. SOW verification was obtained. Negative Media & PEP: There is some negative media against Mr Epstein and he is also maintains a close -elationship with Bill Clinton and Prince Andrew. Please see risk cakulator for more information. Appropriate approval ,vas obtained. • Our review did not identify any red flags and thus there was no need to escalate this case further. • We performed due diligence searches on all parties and did not find the names searched to be on any sanctions ists. Cynthia Rodriguez 8; 24;117 5:25 PM No material changes confirmed by the client via phone on 08/22/2017. No GBSA forms required as determination is already noted on the system. Beneficiaries are all added as parties with DOB, SSN/Passport as, address & IDs ONSHORE APPROVALS Client Facing Professional (CFP): Chuck Walker (Signature) Chuck Walker 8/25/2017 Office Director/Business Head: Steven Mattus (Signature) Steven Mattus 8/29/2017 Regional Office Director: (Signature) NIL Business Risk: (Signature) NIL Compliance: Kshiti) Golani Yoonsun Chung (Signature) Karts) Golani Yoonsun Chung 9/6/2017 9/6/2017 LATAM/INTEFtNATIONAL APPROVALS Client Facing Professional (CFP): (Signature) Account Manager: (Signature) Global Market Team Head (Gl4TH):Sub. Market Team Head (94TH): NIL Business Risk: AML Compliance (Signature) (Signature) (Signature) httpe://dbforcepb.my.salesforce.comiservletserylet I nteg ration?' id =0 I N 3000000009 D i&eid=5003200001 EHPpb&Ic=1 &I nkToken=Vmp F P Sx Na k F4 T 42/43 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0066828 SDNY GM_00213012 EFTA01372918