EFTA Document EFTA01438389

Subject: RE: 2018 Periodic Review of Hi h Risked Accounts ), Butterfly Trust ( ) and Neptune, ) under the SOUTHERN FINANCIAL RELATIONSHIP [I] From: Stewart Oldfield < Date: Wed, 05 Sep 2018 18:03:20 -0400 To: Vijay-A Sawant Cc: Richard Iarossi Mayur Rathod < Bradley Gillin Thanks. Just submitted these. Do you know who is approving on behalf of Andrew Gallivan while he's out? From: Vijay-A Sawant Sent: Wednesday, September 05, 2018 9:34 AM To: Stewart Oldfield < Cc: Richard Iarossi Ma ur Rathod <a; Bradley Gillin < Subject: RE: 2018 Periodic Review of Hi h Risked Accounts ), Butterfly Trust ( ) and Neptune, LLC ) under the SOUTHERN FINANCIAL RELATIONSHIP [I] Importance: High Many thanks Stewart!! Just wanted to remind you that KYC Case#01977700 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, {cid:1 =C7BBF707DF9B04F18f9e8a93df9386909@db.com} Vijay Sawant KYC Case Representative Deutsche CIB Centre Private Limited - Deutsche Bank Group EFTA01438389 Wealth Management Bl, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway Goregaon East, Mumbai - 400063 , India Tel. Mobile From: Stewart Oldfield Sent: Wednesday, September 05 To: Vijay-A Sawant Cc: Richard Iarossi <a; Bradley Gillin Sub'ect: Re: 2018 Periodic Review of High Risked Accounts ( ), Butterfly Trust ( ) and Neptune, ( ) under the SOUTHERN FINANCIAL RELATIONSHIP [I] 2018 6:45 PM Thanks. Will submit this afternoon. Stewart Oldfield, CFA, CAIA Director Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management Mayur Rathod LLC EFTA01438390 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#01977698 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 - Deutsche Bank Group Wealth Mana'ement Tel. Mobil From: Vijay-A Sawant EFTA01438391 Sent: Friday, August 31, 2018 6:04 PM To: Stewart Oldfield Cc: Richard Iarossi <I1MINIMMayur Rathod •MI I; Bradley Gillin allIPPOIONIIIIMIIII> Subject: RE: 2018 Periodic Review of Hi h Risked Accounts ), Butterfly Trust ( ) and Neptune, LLC ) under the SOUTHERN FINANCIAL RELATIONSHIP [I] Importance: High 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 (01790739). 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 Deutsche CIB Centre Private Limited Deutsche Bank Group Wealth Management B1, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway EFTA01438392 India From: Stewart Oldfield Sent: Friday, August 31, 2018 5:52 PM To: Vijay-A Sawant Cc: Richard Iarossi Ma ur Rathod a; Bradley Gillin Sub'ect: Re: 2018 Periodic Review of High 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 Deutsche Bank Trust Company Americas EFTA01438393 Deutsche Bank Wealth Management Securities offered through Deutsche Bank Securities Inc. On Aug 31, 2018, at 7:21 AM, Vijay-A Sawant a wrote: 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. EFTA01438394 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 From: Vijay-A Sawant Sent: Friday, August 24 2018 2:39 PM To: Stewart Oldfield < >; Richard Iarossi Cc: Ma ur Rathod Bradley Gitlin > Sub'ect: RE: 2018 Periodic Review of High Risked Accounts ( ), Butterfly Trust ( ) and Neptune, LLC ( ) 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 EFTA01438395 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, <image001.gif> Vijay Sawant KYC Case Representative Deutsche CIB Centre Private Limited - Deutsche Bank Group Wealth Management ay From: Vijay-A Sawant Sent: Tuesday, July 31 2018 6:31 PM To: Bradley illin Stewart Oldfield Cc: Mayur Rathod Sub'ect: 2018 Periodic Review of Hi h Risked Accounts ( ), Butterfly Trust ( ) and Neptune, under the SOUTHERN FINANCIAL RELATIONSHIP Importance: High EFTA01438396 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 — ndyke, 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 EFTA01438397 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 — 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, <image001.gif> Vijay Sawant EFTA01438398 KYC Case Representative Deutsche CIB Centre Private Limited - Deutsche Bank Group Wealth Management EFTA01438399