EFTA Document EFTA01299302

Cynthia Rodriguez From: Patrick Campion Sent: Friday, October 14, 2016 5:02 PM To: Cynthia Rodriguez Cc: Armen Brash Subject: RE: APPROVAL NEEDED: High Risk KYC Case 01651789 [II Classification: For Internal use only Approved. Just to be accurate, the client was presented to RRC and cleared. Kind regards, Patrick Campion Patrick Campion Managing Director I Head of Wealth Management America Deutsche Bank Trust Company Americas Wealth Management - Americas 345 Park Avenue. 10154-0004 New York, NY. USA Tel Mobile Email From: Cynthia Rodriguez Sent: Friday, October 14, 2016 4:43 PM To: Patrick Campion Cc: Armen Brash Subject: APPROVAL NEEDED: High Risk KYC Case 01651789 Hello, I am requesting Exco Approval for the Butterfly Trust, an existing trust here at DB, under the Jeffrey Epstein relationship. Mr. Epstein has replaced the beneficiaries to this trust, which is the reason for this KYC update. RM Name Stewart Oldfield Business Line US Onshore GCIS # / KYC # 483290/ 01651789 New or Existing Existing relationship since 8/26/2013. A total of 21 deposit accounts and 3 money Relationship? market accounts for multiple entities, 5 brokerage accounts and 1 custody account If yes. please include relationship Total AUMs $224mn. since date. approx a of accounts. AUK etc) Legal name of Account Butterfly Trust Holder(s) Name of UBO(s) Jeffrey Epstein 1 SDNY_GM_00065158 CONFIDENTIAL - PURSUANT TO FED. R.QQN(F IDENTIAL DB-SDNY-0027983 EFTA_00 175658 EFTA01299302 (Please include USOs who own 25% end more: If Mere era multiple layers, please include descnption 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 lnformation on the UBO) Reason for High Risk PEP (YIN) If yes, include details Ar rTnegative 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 I We are updating the beneficiaries to this existing trust account where Jeffrey Epstein is the grantor. 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 2 SDNY_GM_00065159 CONFIDENTIAL - PURSUANT TO FED. R.QP . N (F I DENTIAL DB-SDNY-0027984 EFFA_00175659 EFTA01299303 345 Park Avenue. 101540004 New York, NY, USA Tel F Email 3 SDNY_GM_00065160 CONFIDENTIAL - PURSUANT TO FED. R.CON(F IDENTIAL DB-SDNY-0027985 EFTA_00 175660 EFTA01299304