EFTA Document EFTA01414241

Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I] From: Zbynek Kozelsky Date: Wed, 21 Dec 2016 15:40:57 -0500 To: Stewart Oldfield Vahe Stepanian Amlcompliance Inquiries Cynthia Rodriguez PWM AMLCompliance Cc: Joshua Shoshan Donald Summer Cherie Quigley Classification: For internal use only Danya, Following up on this matter - Stewart and I spoke to the client and the $6.2MM wire represents capital distribution from King Street Capital, which is one of their partnership investments. Thank you Ziggy fcid:image003.png@O1CFFD0A.6F882F501 Zbynek "Ziggy" Kozelsky Director I Branch Administrative Manager Key Client Partners - Americas Deutsche Bank Securities Inc. Deutsche Asset & Wealth Management 345 Park Avenue, 26th Floor EFTA01414241 New York NY 10154 Tel. Email: All trade execution information contained herein is being provided as an accommodation at your request in advance of your receipt of the official trade confirmation(s). Additional trade detail information available upon request. The terms of the trade(s) may be subject to change prior to settlement, and therefore the official trade confirmation(s) and account statements issued by Deutsche Bank shall govern. Deutsche Bank is not responsible for any discrepancy between the informal execution report and the official trade confirmation(s) or account statements. This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received this email in error), please notify the sender immediately and delete the email from your computer. Any unauthorized copying, disclosure or distribution of the material in this email is prohibited. From: Stewart Oldfield Sent: Tuesday, December 20, 2016 10:11 AM To: Vahe Stepanian; Amlcompliance Inquiries; Zbynek Kozelsky; Cynthia Rodriguez; PWM AMLCompliance Cc: Joshua Shoshan; Donald Summer; Cherie Quigley Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# , Alert# SAM1788880 [I] Classification: For internal use only Client is a billionaire. It's not like this is a specific $6mm of his. Most of his wealth comes from investments and advisory fees. From: Vahe Stepanian Sent: Tuesday, December 20, 2016 10:09 AM To: Amlcompliance Inquiries; Zbynek Kozelsky; Cynthia Rodriguez; PWM AMLCompliance; Stewart Oldfield Cc: Joshua Shoshan; Donald Summer; Cherie Quigley Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE EFTA01414242 TRUST, Account# Alert# SAM1788880 [I] Classification: For internal use only We don't know the answer. Are we supposed to reach out to client about this? Thanks, Vahe From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Tuesday, December 20, 2016 9:39 AM To: Zbynek Kozelsky; Cynthia Rodriguez; PWM AMLCompliance; Stewart Oldfield; Vahe Stepanian Cc: Joshua Shoshan; Donald Summer; Cherie Quigley; Amlcompliance Inquiries Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# , Alert# SAM1788880 [I] Importance: High Classification: For internal use only Good Morning: From the initial response below, it appears that a response was given on a different wire in the amount of $23 mil between brokerage and the private bank. Can anyone answer the inquiry regarding the wire from HSBC? fcid:image002.png@OlD24EEF.D6OAFBC01 Incoming: 10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION EFTA01414243 1. Who is the ultimate originator of these funds (i.e. if this is investment income, please give the name of the investment that the funds originate)? Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York, NY 10005 - 2836 Fax: From: Zbynek Kozelsky Sent: Tuesday, December 20, 2016 8:34 AM To: Cynthia Rodriguez ; PWM AMLCompliance ; Stewart Oldfield Vahe Stepanian < Cc: Joshua Shoshan • Donald Summer Amlcompliance Inquiries Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# S Alert# SAM1788880 [I] Classification: For internal use only Dear AML, Please let us know what else you need regarding this HSBC wire so we close the loop. Happy holidays. EFTA01414244 Ziggy {cid:image003.png@O1CFFD0A.6F882F50} Zbynek "Ziggy" Kozelsky Director I Branch Administrative Manager Key Client Partners - Americas Deutsche Bank Securities Inc. Deutsche Asset & Wealth Management 345 Park Avenue, 26th Floor New York, NY 10154 Tel. Email: All trade execution information contained herein is being provided as an accommodation at your request in advance of your receipt of the official trade confirmation(s). Additional trade detail information available upon request. The terms of the trade(s) may be subject to change prior to settlement, and therefore the official trade confirmation(s) and account statements issued by Deutsche Bank shall govern. Deutsche Bank is not responsible for any discrepancy between the informal execution report and the official trade confirmation(s) or account statements. This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received this email in error), please notify the sender immediately and delete the email from your computer. Any unauthorized copying, disclosure or distribution of the material in this email is prohibited. From: Cynthia Rodriguez Sent: Tuesday, December 20, 2016 8:32 AM To: PWM AMLCompliance; Zbynek Kozelsky; Stewart Oldfield; Vahe Stepanian Cc: Joshua Shoshan; Donald Summer; Cherie Quigley; Amlcompliance Inquiries EFTA01414245 Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# , Alert# SAM1788880 [I] Vahe/Donald/Ziggy, Do you need anything from Stew and I for the below request? We provided as much information as we could, but the transaction in question came into the brokerage account from HSBC and not from the private bank. Let us know if you need anything from us in order to complete the below. Thanks! Kind regards, Cynthia Rodriguez fcid:image001.png@OlD0778D.2D49CDD01 Cynthia Rodriguez Assistant Vice President Deutsche Deutsche 345 Park Tel. Fax Email Bank Trust Company Americas Asset & Wealth Management Avenue, 10154-0004 New York, NY, USA From: Danya Friedman On Behalf Of PWM AMLCompliance Sent: Tuesday, December 20, 2016 8:01 AM To: Cynthia Rodriguez; Zbynek Kozelsky; Stewart Oldfield; Vahe Stepanian Cc: Joshua Shoshan; Donald Summer; Cherie Quigley; Amlcompliance Inquiries Subject: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I] Importance: High EFTA01414246 Classification: For internal use only Good Morning: I am writing to follow up on the inquiry below. Please note that this is the 3rd request for information. Please respond ASAP. Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York. NY 10005 - 2836 Fax: From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Wednesday, December 14, 2016 8:56 AM To: CntI mm i - Rocilriuez ; Zbynek Kozelsky ; Stewart Oldfield Vahe St epanian <== > Cc: Joshua Shoshan Smile.; Donald Summer ; Cherie Quigley MMIMMIIIIMIII ; Amlcompliance Inquiries Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# , Alert# SAM1788880 [I] Importance: High Classification: For internal use only Good Morning: EFTA01414247 I am writing to follow up on my inquiry below. Thank you. Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York, NY 10005 - 2836 Fax: From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Monday, December 05, 2016 12:05 PM To: C nthia Rodri uez Zb nek Kozelsk ; Stewart Oldfield ; Vahe St epanian Cc: Joshua Shoshan Donald Summer ; Cherie Quigley Amlcompliance Inquiries =fl Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# NOONIMIMM, Alert# SAM1788880 [I] Importance: High Classification: For internal use only Thank you for the response Cynthia. Team, this is not the wire I am asking about. Please see the incoming wire listed below from HSBC. I see the $23,000,000.00 incoming wire from the Private Bank account and that is not/was never in question. I need to know where these funds originate. 10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION EFTA01414248 Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York. NY 10005 - 2836 Fax: {cid:image002.png@OlD24EEF.D6OAFBC0} From: Cynthia Rodriguez Sent: Monday, December 05, 2016 11:32 AM To: Amlcompliance Inquiries ; Zbynek Kozelsky ; Stewart Oldfield >; Vahe Stepanian ‹ > Cc: Joshua Shoshan Donald Summer <donald.summer@db.com> Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I] All, The originating wire came from the client's account called Southern Trust Company, Inc account number This wire was not submitted through HSBC but through Bank of New York in order to be placed into their N4G account for the art purchase. The beneficiary is our client Jeffery Epstein as the originating party and the art purchaser. Please let me know if you need anything else. Kind regards, Cynthia Rodriguez fcid:image001.png@OlD0778D.2D49CDD01 Cynthia Rodriguez Assistant Vice President EFTA01414249 Deutsche Deutsche 345 Park Tel. ■ Fax Email • Bank Trust Company Americas Asset & Wealth Management Avenue, 10154-0004 New York, NY, USA From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Friday, December 02, 2016 11:36 AM To: Zbynek Kozelsky; Amlcompliance Inquiries; Stewart Oldfield; Vahe Stepanian Cc: Joshua Shoshan; Donald Summer; Cynthia Rodriguez Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# SAM1788880 [I] Classification: For internal use only , Alert# Please specify the originating account so that I can confirm this transaction, after searching PRIME and DB FORCE (our PB systems, I am unable to locate the transaction). Also, any idea as to why, if this is an internal transfer, that funds are being sent through HSBC? Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York, NY 10005 - 2836 Fax: From: Zbynek Kozelsky Sent: Friday, December 02, 2016 11:23 AM To: Amlcompliance Inquiries <amlcompliance.inquiries@db.com>; Stewart Oldfield <a>; Vahe Stepanian Cc: Joshua Shoshan ; Donald Summer ; Cynthia Rodriguez EFTA01414250 Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# , Alert# SAM1788880 [I] Classification: For internal use only Just to clarify, the funds came in from client's Private bank account (in house — from DBTCA account/PB into his DBSI account). Thanks {cid:image003.png@O1CFFD0A.6F882F50} Zbynek "Ziggy" Kozelsky Director I Branch Administrative Manager Key Client Partners - Americas Deutsche Bank Securities Inc. Deutsche Asset & Wealth Management 345 Park Avenue, 26th Floor New York, NY 10154 Tel. Email: All trade execution information contained herein is being provided as an accommodation at your request in advance of your receipt of the official trade confirmation(s). Additional trade detail information available upon request. The terms of the trade(s) may be subject to change prior to settlement, and therefore the official trade confirmation(s) and account statements issued by Deutsche Bank shall govern. Deutsche Bank is not responsible for any discrepancy between the informal execution report and the official trade confirmation(s) or account statements. This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received this email in error), EFTA01414251 please notify the sender immediately and delete the email from your computer. Any unauthorized copying, disclosure or distribution of the material in this email is prohibited. From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Friday, December 02, 2016 11:21 AM To: Stewart Oldfield; Vahe Stepanian; Zbynek Kozelsky; Amlcompliance Inquiries Cc: Joshua Shoshan; Donald Summer; Cynthia Rodriguez Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I] Classification: For internal use only Good Morning and thank you for the quick response. Just to clarify, the below response is only answering my questions regarding the Outgoing Transfers and both of these transfers were towards the purchase of art? We will need the ultimate originator for the Incoming Transfer. Also, once again, just to clarify, we have the KYC on the HAZE TRUST, we need the source of wealth for the beneficiaries if available. Thanks again! I hope everyone has a great weekend! Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York, NY 10005 - 2836 Fax: From: Stewart Oldfield Sent: Friday, December 02, 2016 11:17 AM To: Vahe Stepanian Zbynek Kozelsky •=j ila; Amlcompliance Inquiries EFTA01414252 Cc: Joshua Shoshan ; Donald Summer ; Cynthia Rodriguez Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# SAM1788880 [I] Classification: For internal use only Cynthia is back Monday and will send all of the docs then. Thanks From: Vahe Stepanian Sent: Friday, December 02, 2016 11:11 AM To: Zbynek Kozelsky; Amlcompliance Inquiries Cc: Joshua Shoshan; Donald Summer; Stewart Oldfield Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# SAM1788880 [I] Classification: For internal use only Alert# Alert# Adding Stewart Oldfield, primary relationship manager who can confirm the below. 1. What is the purpose of the Outgoing Transfer? Purchase of Art. 2. What is the relationship between Beneficiary and Client? Per our conversation with client — the beneficiary in this situation is an escrow account in which the cash will be held until art is delivered. EFTA01414253 3. Please provide the source of wealth for these entities. Stewart — can you please add here the Private Bank KYC, which I believe includes the SOW for this client? Thank you. Best, Vahe From: Zbynek Kozelsky Sent: Friday, December 02, 2016 11:03 AM To: Amlcompliance Inquiries Cc: Vahe Stepanian; Daniel Sabba; Joshua Shoshan; Donald Summer Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# SAM1788880 [I] Classification: For internal use only Vahe, Please follow up. Reason — purchase of art. Thanks Alert# {cid:image003.png@O1CFFD0A.6F882F50} EFTA01414254 Zbynek "Ziggy" Kozelsky Director I Branch Administrative Manager Key Client Partners - Americas Deutsche Bank Securities Inc. Deutsche Asset & Wealth Management 345 Park Avenue, 26th Floor New York NY 10154 Tel. Email: All trade execution information contained herein is being provided as an accommodation at your request in advance of your receipt of the official trade confirmation(s). Additional trade detail information available upon request. The terms of the trade(s) may be subject to change prior to settlement, and therefore the official trade confirmation(s) and account statements issued by Deutsche Bank shall govern. Deutsche Bank is not responsible for any discrepancy between the informal execution report and the official trade confirmation(s) or account statements. This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received this email in error), please notify the sender immediately and delete the email from your computer. Any unauthorized copying, disclosure or distribution of the material in this email is prohibited. From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Friday, December 02, 2016 11:01 AM To: Zbynek Kozelsky Cc: Dcarla Oliveira; Tatiana Dominguez; Maurice Abitbol; Amlcompliance Inquiries Subject: Inquiry Regarding THE HAZE TRUST, Account# , Alert# SAM1788880 [I] Classification: For internal use only Good Morning: EFTA01414255 As a part of the anti-money laundering monitoring program, the Actimize system is used to automatically identify transactions that meet certain high risk transaction patterns. When transactions occur which mimic those patterns, the activity must be researched to confirm that it is legitimate. In a small percentage of these cases, Compliance must contact the Wealth Advisor for additional information about the transaction(s) in order to conclude the research process. Your response is required for the Bank to comply with federal guidelines for concluding the research of these matters in a timely fashion. Your complete response must be received within 7 business days. To the best of your ability, please provide details regarding the item(s) below: Incoming: 10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION 1. Who is the ultimate originator of these funds (i.e. if this is investment income, please give the name of the investment that the funds originate)? Outgoing: 11/23/2016, $25,000,000.00, AP NARROWS HOLDING LP/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA, N.A., NY 11/23/2016, $5,000,000.00, LDB 2011 LLC/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA, N.A., NY 1. What is the purpose of the Outgoing Transfer? EFTA01414256 2. What is the relationship between Beneficiary and Client? 3. Please provide the source of wealth for these entities. Thank you in advance for your prompt attention to this matter. Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York, NY 10005 - 2836 Fax: PLEASE NOTE: YOU ARE BEING CONTACTED BECAUSE YOU ARE LISTED AS THE PRIMARY OFFICER FOR THIS ACCOUNT ON GCIS. IF YOU ARE NOT THE CURRENT PRIMARY OFFICER, PLEASE LET ME KNOW IMMEDIATELY, SO THAT I MAY FORWARD THIS EMAIL TO THE APPROPRIATE PARTY. Do not forward this e-mail or any attachment directly to the client. EFTA01414257