EFTA Document EFTA01436172

Subject: RE: 2018 Periodic Review of High Risked Accounts III ( ), Butterfly Trust (GCIS#486426) and Neptune, LLC (GCIS#487264) under the SOUTHERN FINANCIAL RELATIONSHIP [I] From: Vijay-A Sawant ‹ > Date: Fri, 31 Aug 2018 07:21:20 -0400 To: Stewart Oldfield Richard Iarossi Cc: Mayur Rathod Bradley Gillin Hi Stewart, Please see pending confirmations required in KYC Case#01977698 for 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#01790739. Kindly advise on the above so we can complete this case and submit to AML for approval, thanks. Kind Regards, {cid:1 [email protected]} 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 Goregaon East, Mumbai - 400063 , India Tel. EFTA01436172 Mobile From: Vijay-A Sawant Sent: Friday, August 24, 2018 2:39 PM To: Stewart Oldfield ; Richard Iarossi Cc: Mayur Rathod ; Bradley Gitlin Subject: RE: 2018 Periodic Review of High Risked Accounts III ( ), Butterfly Trust (GCIS#486426) and Neptune, LLC (GCIS#487264) under the SOUTHERN FINANCIAL RELATIONSHIP [I] Importance: High 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 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#01790739. We will proceed to the next stages upon receipt of your confirmation of the above queries, thanks. Kind Regards, EFTA01436173 (cid:1 [email protected]} 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 Tel. Mobile From: Vijay-A Sawant Sent: Tuesday, July 31, 2018 6:31 PM To: Bradley Gillin Cc: Mayur Rathod Subject: 2018 Periodic Review of High Risked Accounts ), Butterfly Trust (GCIS#486426) and Neptune, LLC (GCIS#487264) under the SOUTHERN FINANCIAL RELATIONSHIP Importance: High Stewart Oldfield 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 EFTA01436174 Trustees — Harry Beller & Erika Kellerhals UBO's — , Irina , Darren Indyke, 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. 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 EFTA01436175 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, {cid:1 [email protected]} 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 Goregaon East, Mumbai - 400063 , India Tel. Mobile + EFTA01436176