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Classification: Public
Got it.. what is a ...external enhanced due diligence report?
Original Message
The issue is that JE was listed as president of Gratitude America Ltd in the
entity's original articles of incorporation. Additionally, JE was listed as
the source of funds in the initial KYC done by Paul's team.
When Ari reached out to Middle Office, they looked at the KYC and flagged
the request as "high risk" and asked us to get AML approval. As you recall,
we already went to AML (Wayne Salit) to ask whether the account opening
could be done. Wayne was the one who referred us to RRC.
When we went to the RRC, they requested an external updated Enhanced Due
Diligence Report. The entire back and forth over the past week is on the
request for this report, which is under Paul's review for sign-off.
EFTA01409636
In summary, first, the KYC does not reflect this is a separate relationship.
Second, given the post-facto nature of the changes in the article of
incorporation, I think AML/RRC are very likely to still require the due
diligence report.
Thoughts? What is JE's role here?
Begin forwarded message:
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
EFTA01409637
Cc: Todd Stevens; Vahe Stepanian; Mark Frankel
Hi Paul,
That is correct.
Best,
Ari
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
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
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
Paul, thank you for your note. We just double checked and Gratitude
EFTA01409638
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
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
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
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
Hi Paul — I hope all is well. We wanted to circle back on this form. Thank
you, Daniel
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer; Mark Frankel
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?
EFTA01409639
Best regards,
Daniel
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer
Classification: For internal use only
Daniel, can you or Todd please call me to explain this document? Thanks
Paul Morris
Managing Director
Deutsche Bank Private Bank
Cc: Todd Stevens; Vahe Stepanian; Ariane Dwyer
Paul,
EFTA01409640
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
Daniel Sabba
Deutsche Bank Securities Inc.
EFTA01409641