EFTA Document EFTA01299272

Cynthia Rodriguez From: Patrick Campion Sent: Thursday, January 05, 2017 3:46 PM To: Cynthia Rodriguez Cc: Samantha Harmon; Armen Brash Subject: RE: APPROVAL NEEDED: High Risk KYC Case 01704382 [Ij Classification: For Internal use only Approved Kind regards, Patrick Campion Patrick Campion Managing Director I Head of Wealth Management Americas Deutsche Bank Trust Company Americas Wealth Management - Americas 345 Park Avenue. 10154-0004 New York. NY. USA From: Cynthia Rodriguez Sent: Thursday, January 05, 2017 1:16 PM To: Patrick Campion Cc: Samantha Harmon; Armen Brash Subject: APPROVAL NEEDED: High Risk KYC Case 01704382 Importance: High Hello, I am requesting Exco Approval for a new account opening for current DB client Jeffrey Epstein. RM Name Business Line GCIS # / KYC # New or Existing Relationship? If yes. please include relationship since date. approx # of accounts. AUM. etc.) Stewart Oldfield US Onshore Existing relationship since 8/26/2013. A total of 21 deposit accounts and 3 money market accounts for multiple entities, 5 brokerage accounts and 1 custody account. Total AUMs $224mn. Legal name of Account Prytanee, LLC Holder(s) Name of UBO(s) Jeffrey Epstein and Caroline Lang (Please include UBOs who own 1 SDNY_GM_00065110 CONFIDENTIAL - PURSUANT TO FED. R.CDFNIF IDENTIAL DB-SDNY-0027935 EFTA_00I756l0 EFTA01299272 25% and more: It there are multiple layers. please include description of ownership structure) Description of Type of account being opened with detailed purpose of the accounts (Please include SOW information/ Geographic location/ For Entity Accounts: Description of the entity and background information on the UBO) Reason for High Risk PEP (Y/N) If yes. include details Any negative media and/or court cases? Include ALL negative media & court cases If Yes, please give details Business Justification for the relationship despite High Risk Factors Kind regards, Cynthia Rodriguez Cynthia Rodriguez Assistant Vice President We are opening a deposit account for Prytanee LLC. The account will be used to purchase art from up and coming artists. This relationship is deemed high risk due to multiple court cases on Jeffrey Epstein, involving 22 April 2004 SEC filed a settled civil fraud action for illegal insider trading in three publicly traded Massachusetts banks. Final judgement permanently enjoins him from violating the antifruad provisions and he agreed to pay a total of S72532.06 in disgorgement of trading profits, prejudgment interest and civil penalties. Epstein was sentenced to 21 months in federal prison for three counts of fraud, sexually assaulting a girl and solicitation of prostitution. These alerts were previously approved by senior management and AML Compliance. Prior clearance is attached as a reference No Yes Aside from the court cases listed in the reason for high risk, all other alerts were false positives and no new court cases or negative media has come up for this client. All negative media and alerts have been reviewed by AML Compliance and they do not see a reason to discontinue the existing relationship with Jeffrey Epstein. Deutsche Bank Trust Company Americas Deutsche Asset & Wealth Management 345 Park Avenue, 10154-0004 New York. NY. USA 2 SDNY_GM_00065111 CONFIDENTIAL - PURSUANT TO FED. R.ctailf IDENTIAL DB-SONY-0027936 EFTA_00I75611 EFTA01299273 SON,M_00065,2 CONFIDENTIAL- PURSUANT TO FED. R.cONEIDENTIAL DB-SONY-0027937 EFTA,I756I2 EFTA01299274