EFTA Document EFTA01364100

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 Business Line GCIS #/ KYC # New or Existing Relationship? If yes. please include relationship since date. approx It of accounts. AUM, etc.) Legal name of Account Holder(s) Name of UBO(s) (Please include U8Os who own 25% and more: If 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 U80) Reason for High Risk PEP (Y/N) If yes, include details Any negative media and/or court cases? Include ALL negative media .4 court cases 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. Butterfly Trust Jeffrey Epstein 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 $72532.06 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 If Yes, please give details 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. Business Justification for All negative media and alerts have been reviewed by AML Compliance and they CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0054609 CONFIDENTIAL SDNY_GM_00200793 EFTA01364100