EFTA Document EFTA01356712

KYC Print Page 42 of 43 M. Case Comments Created By Date Comments Kshitij Golani 9/25/118 10:04 AM iris KYC serves as a high risk update for the below listed clients (together "accounthdders") - 1.- & Karyna Shuliak . Butterfly Trust . Neptune LLC low are the reasons why we are comfortable with approving this KYC: Information and supporting documents required by our NIL Policy were provided and reviewed; and as a esult, we have an understanding of the structure of the accountholders, their purpose, the purpose of the ccounts and expected transaction activity. There are a few risk factors associated with the accountholders — SOW: The 120 (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages client's ssets. SOW verification was obtained. In addition, Karyna Shuliak is an employee at JSC Interiors. We have her ay stubs under KYC — 1790724. Negative Media & PEP: There is some negative media against Mr Epstein and he is also maintains a close elabonship with Bill Clinton and Prince Andrew. Please see risk calculator for more information. Appropriate pproval was obtained. Our review did not identify any red flags and thus there was no need to escalate this case further. We performed due diligence searches on all parties and did not find the names searched to be on any rictions lists. Mayur Rathod 9/3/118 3:17 AM No material changes confirmation "email' attached in the case. ONSHORE APPROVALS Client Faong Professional (CFP): Stewart Oldfield (Signature) Stewart Oklfield 9/5/2018 Office Director/Business Head: Steven Mattus (Signature) Steven Mattus 9/6/2018 Regional Office Director: (Signature) MIL Business Risk: (Signature) MIL Compliance: Ksb:ui Ge'ant v.: cr-at.,re; ; Cc 1n. 2: 2CIS LATAM/INTERNATIONAL APPROVALS Client Facing Professional (CFP): (Signature) Account Manager: (Signature) Global Market Team Head t GMTH)/Sub-Market Team Head SMTH): (Signature) AML Business Risk: (Signature) littps://dbforcepb.my.salesforce.com/servlet/servlet.Integration9lid=0 IN30000000D9Di&eid=5000e00001 N... 7/10/2019 CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0042710 CONFIDENTIAL SDNY_GM_00188894 EFTA01356712