EFTA Document EFTA01420904

Subject: Re: 2018 Periodic Review of Hi h Risked Accounts , Butterfly Trust and Neptune, LLC 111.11 11. Oldfield under the SOUTHERN FINANCIAL RELATIONSHIP [I] Date: Wed, 05 Sep 2018 10:30:52 -0400 To: Vijay-A Sawant Cc: Richard Iarossi Mayur Rathod Bradley Gillin Great, thanks Stewart Oldfield, CFA, CAIA Director Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 Park Avenue, New York, NY 10154 Securities offered through Deutsche Bank Securities Inc. On Sep 5, 2018, at 9:34 AM, Vijay-A Sawant wrote: > Many thanks Stewart!! Just wanted to remind you that KYC Case#IIIIIIII also requires your review and submission to AML as per attached email. This case has 2 other accounts, so we will have 5 high risked accounts submitted today. .7 Kind Regards, <image001.gif> Vijay Sawant EFTA01420904 KYC Case Representative Deutsche CIB Centre Private Limited Wealth Management Bl, DB Centre Mumbai, Nirlon Knowledge Gore aon East, Mumbai - 400063 , India Deutsche Bank Group Park, Western Express Highway From: Stewart Oldfield Sent: Wednesday, September 05, 2018 6:45 PM To: Vijay-A Sawant Cc: Richard Iarossi Subject: Re: Mayur Rathod ; Bradley Gillin 2018 Periodic Review of High Risked Accounts , Butterfly Trust and Neptune, LLC under the SOUTHERN FINANCIAL RELATIONSHIP [I] Thanks. Will submit this afternoon. Stewart Oldfield, CFA, CAIA Director Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 Park Avenue, New York, NY 10154 Tel. Mobile EFTA01420905 Email Securities offered through Deutsche Bank Securities Inc. On Sep 5, 2018, at 9:05 AM, Vijay-A Sawant wrote: Good Morning Stewart, We have completed KYC Case for the above high risked accounts and re-assigning this case to you for your approval. Request you to kindly advise if any discrepancies, or else forward to the AML team for final approval, thanks. Kind Regards, <image001.gif> Vijay Sawant KYC Case Representative Deutsche CIB Centre Private Limited Wealth Management Bl, DB Centre Mumbai, Nirlon Knowledge Goregaon East, Mumbai - 400063 , India Deutsche Bank Group Park, Western Express Highway EFTA01420906 From: Vijay-A Sawant Sent: Friday, August 31, 2018 6:04 PM To: Stewart Oldfield Cc: Richard Iarossi Bradley Gillin Subject: RE: 2018 Periodic Review of High Risked Accounts- , Butterfly Trust and Neptune, LLC under the SOUTHERN FINANCIAL RELATIONSHIP [I] Importance: High Mayur Rathod Hi Stewart, Thanks for the confirmation on Butterfly Trust. We confirm that we do not require CDD form for this account & everything ok with this acct. For Neptune, we agree that we have all docs for Richard Kahn. The only reason we clarified below is because he was missing as RP, from the previously approved KYC . However as per documentation evidence, we confirm he needs to be added. Anyways, we will be submitting this case by Monday when all searches are complete. I am available for another hour today, are you free for a call now? Kind Regards, <image001.gif> Vijay Sawant KYC Case Representative EFTA01420907 Deutsche CIB Centre Private Limited - Deutsche Bank Group Wealth Management B1, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway Gore aon East, Mumbai - 400063 , India From: Stewart Oldfield Sent: Friday, August 31, 2018 5:52 PM To: Vijay-A Sawant Cc: Richard Iarossi ; Mayur Rathod Bradley Gillin Subject: Re: 2018 Periodic Review of Hi h Risked Accounts , Butterfly Trust and Neptune, LLC under the SOUTHERN FINANCIAL RELATIONSHIP [I] Butterfly is a personal trust. For Neptune, any reason not to just add Rich as an RP? We've already KYC'd him for other accounts, correct? Will call you at 9 or so. Thanks Stewart Oldfield, CFA, CAIA Director EFTA01420908 Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 Park Avenue, New York, NY 10154 Tel. Mobile Email Securities offered through Deutsche Bank Securities Inc. On Aug 31, 2018, at 7:21 AM, Vijay-A Sawant wrote: Hi Stewart, Please see pending confirmations required in KYC Case9aor Butterfly & Neptune, below — Butterfly trust — Kindly confirm if this is a Personal Trust and NOT Corporate Trust? After reviewing the trust agreement, we noticed that the UBO's seem not related to the grantor. The reason for this request is to evaluate whether we require CDD form for this account or not. NOTE: we require CDD form ONLY in case of Corporate Trusts. Neptune LLC — Please note that Richard Kahn has been added as manager as per Operating Agreement even though he was NOT added as an RP in the previously approved KYC Case! EFTA01420909 Kindly advise on the above so we can complete this case and submit to AML for approval, thanks. Kind Regards, <image001.gif> Vijay Sawant KYC Case Representative Deutsche CIB Centre Private Limited - Deutsche Bank Group Wealth Management Bl, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway Gore aon East, Mumbai - 400063 , India From: Vijay-A Sawant Sent: Friday, August 24, 2018 2:39 PM Cc: Mayur Rathod Richard Iarossi Bradley Gitlin ' • • Periodic Review of Hi h Risked Accounts Butterfly Trust and Neptune, LLC under the SOUTHERN FINANCIAL RELATIONSHIP [I] Hello Richard, We have received material change confirmation from Brad on below accounts as per attached email. So following are list of items pending on these accounts EFTA01420910 Butterfly trust — Kindly confirm if this is a Personal Trust and NOT Corporate Trust? After reviewing the trust agreement, we noticed that the UBO's seem not related to the grantor. The reason for this request is to evaluate whether we require CDD form for this account or not. NOTE: we require CDD form ONLY in case of Corporate Trusts. Neptune LLC — Please note that Richard Kahn has been added as manager as per Operating Agreement even though he was NOT added as an RP in the previously approved KYC Case We will proceed to the next stages upon receipt of your confirmation of the above queries, thanks. Kind Regards, <image001.gif> Vijay Sawant KYC Case Representative Deutsche CIB Centre Private Limited - Deutsche Bank Group Wealth Management B1, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway Goregaon East, Mumbai - 400063 , India From: Vijay-A Sawant Sent: Tuesday, July 31, 2018 6:31 PM To: Bradley Gillin Cc: Mayur under the Rathod eriodic Review of Hi h Ri k Accounts Butterfly Trust and Neptune, LLC MM. SOUTHERN FINANCIAL RELATIONSHIP >; Stewart Oldfield EFTA01420911 Importance: High Hello Brad/Stewart, This review relates to above high risked three accounts due for remediation 08/31/2018. Upon review of the docs available in the repositories, we have completed the attached checklist, main RP's also listed below for reference — Acct Holder — Butterfly Trust Grantor — Jeffrey Epstein Trustees — Harry Beller & Erika Kellerhals UBO's — arren nd ke, Karyna Shuliak, Richard Kahn, & Following are list of required items — Confirm whether material changes to account or not & RP's identified above are correct? Volcker Questionnaire completed reflects this trust as a "Family Trust" but this seems inaccurate. All UBO's have different surnames and some even different nationalities. Please advise if ok to accept? I have attached the questionnaire in this email for reference. Depending on the response to above bullet point, we might require CDD form if this trust is deemed to be Corporate trust. EFTA01420912 Acct Holder — Neptune LLC Sole Member & Shareholder — Jeffrey Epstein Manager — Richard Kahn Authorized Signers — Harry Beller & Darren Indyke Following are list of required items — Confirm whether material changes to account or not & RP's identified above are correct? Fincen CDD form required, attached blank form for reference Acct Holder & Authorized Signatory — Joint Acct Holder & Authorized Signatory — Karyna Shuliak SOW Company (for Karyna Shuliak) — JSC Interiors LLC Following are the list of required items — Confirm whether material changes to account or not? Kindly advise at the earliest on the above so I can launch KYC for all accounts and begin remediation, thanks. Kind Regards, EFTA01420913 <image001.gif> Vijay Sawant KYC Case Representative Deutsche CIB Centre Private Limited - Deutsche Bank Group Wealth Management Bl, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway - 400063 , India <mime-attachment> EFTA01420914