EFTA Document EFTA01401833

Subject: Southern Financial LLC - KYC and credit derivatives/convertible bonds onboarding [C] From: Martin Zeman < Date: Wed, 14 Mar 2018 17:08:50 -0400 To: Zack Bunimovich Rita Shteynber Jitan Patel Cc: Xavier Avila Liam Osullivan Mathew Negus Alastair Mackinlay Davide-A Sferrazza Anthony Lentini Classification: Confidential Zack, See attached for what Nina Tona sent in the last email in this chain and I am adding the Formation Document. This should complete everything you asked for in your email from March 13. We have a pending trade with the client in credit derivatives next week. Can you please put this as a priority? Source of Wealth: The source of wealth is Jeffrey Epstein as the sole shareholder. Jeffery Epstein began his financial career in 1976 as an options trader at Bear Stearns and became a partner in 1980. In 1982, Epstein founded his own financial management firm, J. Epstein & Co., managing the assets of clients with more than a billion in net worth. In 1996, Epstein changed the name of his firm to The Financial Trust Company and based it on the island of St. Thomas in the US Virgin Islands, which merged into Southern Financial LLC. All of his clients were anonymous except for the very wealthy businessman Leslie Wexner. His wealth has come from his days at Bear Stearns and his financial management firms. Client Contact: Richard Kahn EFTA01401833 212-971-1306 Formation Document: Attached LLC Documents include the Articles of Organization, Thanks, Martin From: Nina Tona Sent: Tuesday, March 13, 2018 11:41 AM To: Zack Bunimovich ; Xavier Avila Cc: Rita Shte nber ; Jitan Patel ; Davide-A Sferrazza Anthony Lentini Subject: RE: SF [I] [C] ; Martin Zeman ; Mathew Negus Classification: Confidential Zack, ; Alastair Mackinlay I believe some of the below was already provided back in Feb. Please review below and attached to make sure they are sufficient and we'll get back on the additonal. Ownership - Broken down to 10% (Org chart with %'s of ownership or confirmation from Senior Client Rep explaining the ownership breakdown) EFTA01401834 Legal Reps — Identify and Verify UBO's - Identify and Verify Source of Funds — Identification & Verification (Annual Report) Source of Wealth — Identify and Verify Client Contact for Patriot Act disclosure email Formation Document (Cert of Incorp, etc) Nature of Business Doc Organization Chart o Per attachment "Southern Financial Operating Agreement" (pages 1, 16) § Southern Trust Company Inc. is the sole member of Southern Financial LLC § Jeffrey Epstein is the sole shareholder of Southern Trust Company Inc. UBOs (Owners) that own greater than 10% o Jeffrey Epstein is the sole UBO (see "Organization Chart" above) The source of funds for the UBOs (owners) that are greater than 10% o Jeffery Epstein began his financial career in 1976 as an options trader at Bear Stearns and became a partner in 1980. In 1982, Epstein founded his own financial management firm, J. Epstein & Co., managing the assets of clients with more than a billion in net worth. In 1996, Epstein changed the name of his firm to The Financial Trust Company and based it on the island of St. Thomas in the US Virgin Islands, which merged into Southern Financial LLC. All of his clients were anonymous except for the very wealthy businessman Leslie Wexner. His wealth has come from his days at Bear Stearns and his financial management firms. EFTA01401835 List of Legal representatives o Per attachment "Southern Financial Operating Agreement" (pages 16) § Jeffrey Epstein, Darren K. Indyke, Richard Kahn Annual report o See attachments "Southern Financial LLC Financials June 2017" and "Southern Trust Company Inc. Financials June 2017" for latest financial statements Thank you Nina Tona From: Zack Bunimovich Sent: Tuesday, March 13 2018 11:16 AM To: Martin Zeman ; Xavier Avila Cc: Nina Tona ; Rita Shteynberg Mathew Negus < >; Jitan Patel Alastair Mackinlay < ; Davide-A Sferrazza <davide- >; Anthony Lentini Subject: RE: SF [I] [C] Classification: Confidential Hi Martin, I just received the finalized KYC review yesterday. Even though the entity is opened for other products, it is outside of its KYC review date and is EFTA01401836 triggering a high risk rating. In order to approve the account, the team will need the following: Ownership - Broken down to 10% (Org chart with %'s of ownership or confirmation from Senior Client Rep explaining the ownership breakdown) Legal Reps — Identify and Verify UBO's - Identify and Verify Source of Funds — Identification & Verification (Annual Report) Source of Wealth — Identify and Verify Client Contact for Patriot Act disclosure email Formation Document (Cert of Incorp, etc) Nature of Business Doc Thanks, Zack From: Martin Zeman Sent: Monday, March 12, 2018 10:19 AM To: Zack Bunimovich Cc: Nina Tona Mathew Negus < Alastair Mackinla >; Zach Price Subject: RE: SF [I] [C] Classification: Confidential Morning Zack, Xavier Avila Rita Shteynbera>; ; Jitan Patel ; Davide-A Sferrazza <davide- We haven't heard back from you on Friday. Can you let us know what the EFTA01401837 timeline looks like today please? Subject: Re: SF [I] Thanks, Martin From: Zack Bunimovich Sent: Friday, March 09, 2018 11:30 AM To: Xavier Avila ; Martin Zeman Cc: Nina Tona ; Rita Shteynberg Mathew Negus >; Jitan Patel Alastair Mackinla Davide-A Sferrazza <davide Zach Price - Subject: RE: SF [I] [C] Classification: Confidential Xavier, The fund was still undergoing a KYC review per my last contact with the team. I will check again today. Thanks, Zack From: Xavier Avila Sent: Friday, March 09, 2018 10:32 AM To: Martin Zeman Cc: Nina Tona Rita Shte nber ; Zack Bunimovich <a• ; Mathew Ne us ; Jitan Patel ; Alastair Mackinlay ; Davide-A Sferrazza EFTA01401838 Zack, what is the status on this urgent request? Xavier Avila Managing Director Deutsche Bank Securities Inc Mobile: Email: On Mar 5, 2018, at 15:09, Martin Zeman < › wrote: Classification: For internal use only Zack, Please go ahead and set them up for credit derivatives as well as convertible bonds. The credit derivatives is a priority and rather urgent. Client is ready to trade. Thanks Martin From: Nina Tona Sent: Monday, March 05, 2018 3:07 PM To: Martin Zeman ; Zack Bunimovich Xavier Avila < Aa Shteynberg > ; Mathew Negus . Jitan Patel EFTA01401839 Cc: Alastair Mackinlay ; Davide-A Sferrazza ; Mathew Negus Subject: RE: SF [I] Classification: For internal use only Martin — Please confirm we don't need SF to be extended for anything else besides credit derivatives and the products already onboarded. Thank you Nina Tona From: Zack Bunimovich Sent: Monday, March 05, 2018 12:58 PM To: Xavier Avila Mathew Negus Rita lber ; Jitan Patel Cc: Alastair Mackinlay ; Martin Zeman ; Davide-A Sferrazza Mathew Negus ; Nina Tona Subject: RE: SF [I] Classification: For internal use only Hi Xavier, Nothing else is needed from your end at the moment. I will send this request to the KYC team for review and then setup. Can you confirm Credit Derivatives is the only necessary extension? I know Convertible Bonds were also in the discussion. EFTA01401840 I see the BR 1007494283 set up for a decent amount of products already. See below. <image001.jpg> Thanks, Zack From: Xavier Avila Sent: Monday, March 05, 2018 11:45 AM To: Rita Shte nber ; Mathew Negus ; Zack Bunimovich Cc: Alastair Mackinlay ; Davide-A Sferrazza Mathew Negus ; Nina Tona Subject: RE: SF [I] Thanks Rita. Zack, let us know what next steps are. From: Rita Shteynberg Sent: Monday, March 05, 2018 11:08 AM To: Xavier Avila Jitan Patel Cc: Alastair Mackinlay ; Davide-A Sferrazza Mathew Negus >; Nina Tona Subject: RE: SF [I] Martin Zeman ; Mathew Negus < ; Zack Bunimovich ; Martin Zeman EFTA01401841 Including Zack who will be the case manager on this. From: Xavier Avila Sent: Monday, March 05 To: Rita Shte nber Cc: Alastair Mackinlay Mathew Negus < Subject: RE: SF [I] , 2018 10:59 AM Jitan Patel Davide-A Sferrazza >; Nina Tona ; Mathew Negus ; Martin Zeman Hi Rita/Mat, let us know what we need to extend SF to Credit Derivatives as the client is still live in one trade they want to execute. Thanks From: Rita Shteynberg Sent: Friday, March 02, 2018 12:41 PM To: Mathew Negus Varle ; GM ACO ; lain Macara Cc: Alastair Mackinlay Anwar Bunimovich Subject: RE: SF [I] ; Nina Tona <~ >; Jane ; Xavier Avila ; Jitan Patel Davide-A Sferrazza >; Tanushree Kirti Martin Zeman Thanks for the confirmation. We will proceed with the onboarding. From: Mathew Negus Sent: Friday, March 02, 2018 12:34 PM ; Aziz ; Zack EFTA01401842 Subject: RE: SF [I] To: Nina Tona ; Jane Varlet' ; GM ACO ; Xavier Avila ; lain Macara ; Rita Shteynberg ; Jitan Patel Cc: Alastair Mackinlay ; Martin Zeman ; Davide-A Sferrazza -; Aziz >; Tanushree Kirti I'll take this one for Jitan. As CIB green please proceed with the NCA process and the inherent KYC update. Thank you Mathew Negus Director I ICG Business Management I +1(212)250-6746 From: Nina Tona Sent: Friday, March 02, 2018 12:22 PM To: Jane Varlet' ; GM ACO Cc: Alastair Mackinlay ; Davide-A Sferrazza Anwar Tanushree Kirti Subject: RE: SF [I] Importance: High ; Xavier Avila ; Rita Shteynberg ; Mathew Negus Martin Zeman ; Aziz Classification: For internal use only EFTA01401843 Jane — NCA is still in progress. Rita and her team are working on it. They stopped the NCA once they found out it was in red. Jitan will inform them now to complete the NCA. @Jitan — Please inform Rita to continue with the NCA. Thank you Nina Tona From: Jane Varley Sent: Friday, March 02, 2018 11:04 AM To: GM ACO ; Xavier Avila ; lain Macara ; Rita Shteynber ; Jitan Patel ; Mathew Negus Cc: Nina Tona ; Alastair Mackinlay Sferrazza < ; Martin Zeman ; Davide-A ; Aziz Anwar • Tanushree Kirti < Subject: RE: SF [I] Classification: For internal use only +Aziz and Tanu Hi Monika, This was a WM US retain from the Offboarding Clearing House process, that currently reflects in the overall CIB file colour (not coverage colour). Hence green. EFTA01401844 Nina — was NCA completed? We can't see it reflected in dbCAR (still appears delinquent) but I know that is part of the broader conversation that Julia is having with Paul Chapman. Thanks Jane From: Monika Valantiejute On Behalf Of GM ACO Sent: 02 March 2018 15:22 To: Xavier Avila ; lain Macara Rita Shteynber ; Jitan Patel Mathew Negus >; Jane Varley Cc: Nina Tona ; Alastair Mackinlay ; Martin Zeman < >; Davide-A Sferrazza Subject: RE: SF [I] Classification: For internal use only Hi Xavier The GB adoption location is Red across all business but this is CIB Green for the US adoption location — as one of the businesses has asked to retain this. @Jane please confirm which business asked to retain? In these instances, the GM products will not be offboarded if another business has asked to retain and the KYC/ACO responsibility sits with that business. However, please also be aware that this is a High Risk client which is KYC deficient and was last reviewed in 2015. EFTA01401845 Please let me know if any other questions. Kind regards, <image002.png> Monika Valantiejute GM Project Mercury Deutsche Bank Winchester House, 1 Great Winchester Street, London, EC2N 2DB Tel. +44 (0) 2075410657 Email From: Xavier Avila Sent: 02 March 2018 13:53 To: GM ACO Shteynberg ; lain Macara ; Rita ; Jitan Patel Mathew Negus Cc: Nina Tona ; Alastair Mackinla Martin Zeman ; Davide-A Sferrazza Subject: RE: SF [I] EFTA01401846 Thanks Monica, did we hear anything back? The client is asking questions and we have no clear answers or timeframe to give him. Thanks Xavier Avila Managing Director Deutsche Bank Securities Office: +1 212 4542892 Mobile: From: GM ACO < M> Date: Thursday, Mar 01, 2018, 15:09 To: Xavier Avila , Iain Macara , Rita Shteynber , Jitan Patel , Mathew Negus , GM ACO > Cc: Nina Tona , Alastair Mackinlay , Martin Zeman Davide-A Sferrazza Subject: RE: SF [I] Classification: For internal use only Hi Xavier I've reached out to Central Mercury to find out the CIB colour - I will update as soon as I hear back. Kind regards, EFTA01401847 <image002.png> Monika Valantiejute GM Project Mercury Deutsche Bank Winchester House, 1 Great Winchester Street, London, EC2N 2DB Tel. +44 (0) 2075410657 Email From: Xavier Avila Sent: 01 March 2018 19:25 To: lain Macara ; Mathew Negus ; Rita Shteynberg Cc: Nina Tona ; Alastair Mackinlay ; Martin Zeman <a; Davide-A Sferrazza < Subject: RE: SF [I] GM ACO, can you pls let us know what the issue is? We have a client trying to execute a transaction. Thanks EFTA01401848 From: lain Macara Sent: Thursday, March 01, 2018 11:48 AM To: Xavier Avila ; Rita Shteynberg ; Mathew Negus Cc: Nina Tona ; Alastair Mackinlay ; Martin Zeman < >; Davide-A Sferrazza < Subject: RE: SF [I] Gm ACO — can you liaise with central merc and establish the CIB colour on the rhp below? thx From: Xavier Avila Sent: 01 March 2018 16:08 To: lain Macara ; J ; RitaSite ber itan Patel ; Mathew Negus Cc: Nina Tona ; Alastair Mackinla Martin Zeman ; Davide-A Sferrazza Subject: SF Ian, thanks for the call. So Rita who is the Case Manager seems to suggest that she sees Southern Financial Red and therefore we cannot extend it to Credit Derivatives, while we think we should see this Green from a KCP perspective. Bu you explain to me that the Red might be only when it comes to your ICG world. Can you pls clarify if this client is Red for everyone including KCP and if so how do we turn it Green, as discussed this is an example of a KCP EFTA01401849 Americas account that is ACOed by us, in this case myself. Thanks Xavi From: Nina Tona Sent: Thursday, March 01, 2018 11:00 AM To: Xavier Avila ‹ > Subject: SF <image003.png> Kind regards, <image004.gif> Nina Tona Associate Business Control Manager, Key Client Partners — Americas Deutsche Bank Wealth Management 5022 Gate Parkway Jacksonville, Florida 32256 Tel. +1(904)271-3445 Email KCP products and services are intended and available only for persons who are sophisticated institutional investors within the meaning of the FINRA Rule 4512(C)(3), and who are capable of evaluating the strategies, characteristics and investment risks of, and exercising independent judgment in evaluating, the ideas and products discussed herein. Trades and transactions are subject to relevant internal approvals of DBSI or its EFTA01401850 affiliates prior to execution, and the execution of any transaction or idea discussed herein is conditional on your becoming a client of Deutsche Bank. Key Client Partners (KCP) products, investment ideas and solutions and related matters discussed herein are provided for discussion purposes only, and strictly on a non-advisory basis. The KCP Americas desk does not provide investment advice. The information set forth herein is confidential and personal to you and is being presented for your information and for discussion purposes only. Any reproduction and/or redistribution thereof (in whole or in part) or disclosure of its content without our written consent is strictly forbidden. This communication does not create any legally binding obligation on the part of DBSI or any of its affiliates. EFTA01401851