EFTA Document EFTA01365164

From: Stepanian Sent: 2/1/2016 8:57:39 AM To: Daniel Sabba CC: Ariane Dwyer Subject: RE: Epstein account opening III Classification: For Internal use only Updated per your request: Jeffrey E. Epstein was listed as initial president of Gratitude America Ltd, therefore, we wanted to make sure to go through the proper channels such that risk is mitigated from the bank's perspective. As per guidance from Wayne Salit (in AML) — the Southern Financial relationship can transact in existing accounts. If a new account is requested, our understanding is that we must bring the request to his team's attention for approval. Separately, when we reached out to PCS Middle Office to open the new Gratitude Pershing account, they flagged the request as "high risk" — ultimately requiring AML approval. Therefore, Wayne recommended a review by Reputational Risk Committee (RRC), who requested the updated Enhanced Due Diligence Report. The request for this report was sent to Paul for his signoff as Relationship Manager for Southern Financial LLC. Original Message From: Daniel Sabba Sent: Friday, January 29, 2016 05:00 PM Eastern Standard Time To: Vahe Stepanian; Ariane Dwyer Subject: RE: Epstein account opening [1] Please articulate an answer for me to send since you are in the weeds. Original Message From: Todd Stevens Sent: Friday, January 29, 2016 01:59 PM Pacific Standard Time To: Daniel Sabba Subject: Fwd: Epstein account opening [I] Thoughts? What is JE's role here? Begin forwarded message: From: Paul Morris Date: January 29, 2016 at 2:03:59 PM EST To: Todd Stevens Subject: FW: Epstein account opening Classification: For Internal use only Todd, so why are we doing this? This should be separate relationship Paul Morris Managing Director Deutsche Bank Private Bank CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0055827 CONFIDENTIAL SDNY_GM_00202011 EFTA01365164