EFTA Document EFTA01373384

Cc: CAGNY NCA; Manikandan Muralidharan; Sujith Shetty; US-CB S-AML; Anastasia Pringle; Kumud Sharma Subject: RE: EDD package for the RID : ONB-120902 LKYCUS-3443 Party name : Southern Financial LLC [I] Classification: For internal use only HI Dmitri, The UBO is the sole controlling person of our entity however the Board of Directors who executed the operating agreement are the part of the Parent company. We have Considered the confirmation from the BOD of the parent entity which is an independent execution. While the procedure indicated to accept the UBO confirmation provided by the board of director either through an client email or Letter head or formal legal agreements. Kindly provide your view on the same Kind regards. Jofin Varghese Client Onboarding - NY CAC DBOI Global Services Private Limited IB operations Velankani Tech ark No 43 Electronic City, Hosur Road„ 560100 Bangalore, India Tel. Mobile Email Escalation Point Back Up: Dmitri Saks---12117/2014 08:30:54 PM--Classification: For internal use only Hi Jofin, From: To Cc. DJEO Subject 12/17/2014 08:30 PM RE: EDD package for the RID : ONB-120902 LKYCUS-3443 Pity name : Southern Financial LLC III Classification: For Internal use only Hi Jofin, As stated in the attached, Jeffrey Epstein is the only control person, hence the "conflict of interest supposition" still exists. Besides, the supplied Board of Directors paper is neither notarized/witnessed/certified nor represents a formal filing document. In other words, it is not a strong legal proof. In such cases we recommend requesting a letter/email from an internal or external legal counsel. Thanks and regards, Dmitri CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0067536 CONFIDENTIAL SDNY_GM_00213720 EFTA01373384