EFTA Document EFTA01409534

Subject: RE: Epstein account openin [I] From: Vahe Stepanian Date: Mon, 01 Feb 2016 08:57:39 -0500 To: Daniel Sabba Cc: Ariane Dwyer Classification: For internal use only Updated per your request: Jeffrey E. Epstein was listed as initial president of Gratitude America Ltd, therefore, we wanted to make sure to go through the proper channels such that risk is mitigated from the bank's perspective. As per guidance from Wayne Salit (in AML) — the Southern Financial relationship can transact in existing accounts. If a new account is requested, our understanding is that we must bring the request to his team's attention for approval. Separately, when we reached out to PCS Middle Office to open the new Gratitude Pershing account, they flagged the request as "high risk" — ultimately requiring AML approval. Therefore, Wayne recommended a review by Reputational Risk Committee (RRC), who requested the updated Enhanced Due Diligence Report. The request for this report was sent to Paul for his signoff as Relationship Manager for Southern Financial LLC. Original Message From: Daniel Sabba Sent: Friday, January 29, 2016 05:00 PM Eastern Standard Time To: Vahe Stepanian; Ariane Dwyer Subject: RE: Epstein account opening [I] Please articulate an answer for me to send since you are in the weeds. Original Message From: Todd Stevens Sent: Friday, January 29, 2016 01:59 PM Pacific Standard Time To: Daniel Sabba Subject: Fwd: Epstein account opening [I] Thoughts? What is JE's role here? Begin forwarded message: From: Paul Morris a Date: January 29, 2016 at 2:03:59 PM EST To: Todd Stevens a Subject: FW: Epstein account opening [I] EFTA01409534 Classification: For internal use only Todd, so why are we doing this? This should be separate relationship Paul Morris Managing Director Deutsche Bank Private Bank From: Ariane Dwyer Sent: Friday, January 29, 2016 1:59 PM To: Paul Morris; Daniel Sabba Cc: Todd Stevens; Vahe Stepanian; Mark Frankel Subject: RE: Epstein account opening [I] Hi Paul, That is correct. Best, Ari From: Paul Morris Sent: Friday, January 29, 2016 1:54 PM To: Ariane Dwyer; Daniel Sabba Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel Subject: RE: Epstein account opening [I] EFTA01409535 Classification: For internal use only So Ari we confirmed that JE is not an officer and not source of funding of this foundation correct? I'll look at form you sent over now. thx From: Daniel Sabba Sent: Tuesday, January 26, 2016 1:18 PM To: Paul Morris Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel Subject: RE: Epstein account opening [I] Paul, thank you for your note. We just double checked and Gratitude America's formation docs lists JE as president and the entity's KYC lists JE as source of funds. Please complete the request form whenever possible — Ari can help. Thank you, Daniel From: Paul Morris Sent: Tuesday, January 26, 2016 12:59 PM To: Daniel Sabba Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel Subject: RE: Epstein account opening [I] Daniel, isn't Gratitude America a 501-3c? Epstein is not an officer of this and don't think was funded with his $. I'll be back in NY Thursday. If we still need to do the external due diligence on this one let me know and I can do over the phone with Ari and you can submit. Thanks Original Message From: Daniel Sabba Sent: Monday, January 25, 2016 04:40 PM Eastern Standard Time To: Daniel Sabba; Paul Morris EFTA01409536 Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel Subject: RE: Epstein account opening [I] Hi Paul — I hope all is well. We wanted to circle back on this form. Thank you, Daniel From: Daniel Sabba Sent: Thursday, January 21, 2016 3:37 PM To: Paul Morris Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel Subject: RE: Epstein account opening [I] Paul — I am CCing Mark Frankel, who is the best person to answer any questions on this document, as it was produced by his division. Mark, can you please connect with Paul Morris with regards to his questions? Best regards, Daniel From: Paul Morris Sent: Thursday, January 21, 2016 3:13 PM To: Daniel Sabba Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer Subject: RE: Epstein account opening [I] Classification: For internal use only Daniel, can you or Todd please call me to explain this document? Thanks Paul Morris EFTA01409537 Managing Director Deutsche Bank Private Bank From: Daniel Sabba Sent: Thursday, January 21, 2016 11:03 AM To: Paul Morris Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer Subject: Epstein account opening Paul, Per our conversation, the reputational risk committee has requested an external due diligence report as a step towards the approval for opening an account for Gratitude America. This report takes about eight business days to be completed, but we need you to please complete the attached request form to get it started. The committee has informed us DB personnel cannot disclose to the client this matter is being evaluated for reputation matters. They have asked that, when inquired, we communicate to the client "we are in the process of internal due diligence to review the opening of this account, as it is done with all new accounts". Ari can help fill in any information you need in this form. Thank you in advance, Daniel EFTA01409538 Daniel Sabba Deutsche Bank Securities Inc. Email EFTA01409539