EFTA Document EFTA01362433

KYC Print Page 33 of 34 M. Case Comments Created By Date Comments Cynthia Rodriguez 7/6/117 2:41 AM Client was contacted via phone on 6/28/2017 to confirm there are no material changes to his single member LLCs at DB Kshiti) Golani 8/19/117 1:06 AM This KYC serves as a high risk update for the below listed clients (together "accountholders") — 1. Zarro Management, LLC 2. LSJE, LLC 3. Mort, Inc 4. Jeepers Inc S. Hyperion Air, LLC 6. Plan D LLC 7. JEGE LLC 8. JEGE Inc Below are the reasons why we are comfortable with approving this KYC: • Information and supporting documents required by our AML Policy were provided and reviewed; and as a result, we have an understanding of the structure of the accountholders, their purpose, the purpose of the accounts and expected transaction activity. • There are a few nsk factors associated with the accountholders — SOW: The UBO (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages client's assets. SOW verification was obtained. Negative Media & PEP: There is some negative media against Mr Epstein and he is also maintains a close relationship with Bill Clinton and Prince Andrew. Please see risk calculator for more information. Appropriate approval 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 sanctions lists ONSHORE APPROVALS Client Facing Professional (CFP): stewart oldfield (Signature) stewart oldfield 6/29/2017 Office Director/Business Head: Andrew F Gallivan (Signature) Andrew F Gallivan 7/5/2017 Regional Office Director: (Signature) AML Business Risk: (Signature) AML Compliance: Kshiti) Golani Yoonsun Chung (Signature) Kshitg Golani Yoonsun Chung 8/18/2017 8/18/2017 LATAM/INTERNATIONAL APPROVALS Client Facing Professional (CFP): (Signature) Account Manager: (Signature) Global Market Team Head (GMTH)/Sub-Market Team Head (SMTH): (Signature) AML Business Risk: (Signature) https://dbforcepb.my.salesforce.com/servlet/senflet.Integration?lid=01N30000000D9Di... 8/2/2018 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0051839 CONFIDENTIAL SDNY_GM_00198023 EFTA01362433