EFTA Document EFTA01372830

7 15 2019 KYC Print M. Case Comments Created By Date Comments K4,15t) Gclani 9/25/118 10:04 AM as a high risk update for the below listed clients (together -accountholders") — e 1T.I & Karyna Shuliak 2. rust 3. Neptune LLC 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 risk factors associatedwith the accountholders - SOW: The 000 (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages client's assets. SOW verification was obtained. In addition, Karyna Shuliak is an employee at JSC Interiors. We have her pay stubs under KYC — 1790724. Negative Media & PEP: There is some negative media against Mt Epstein and he is also maintains a dose 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 ists. Mayur Rathod 9/3/118 3:17 AM No material changes confirmation 'email" attached in the case. ONSHORE APPROVALS Client Facing Professional (CFP): Stewart Oldfield (Signature) Stewart Oldfield 9/5/2018 Office Director/Business Head: Steven Mattus (Signature) Steven Mattus 9/6/2018 Regional Office Director: (Signature) AK Business Risk: (Signature) AML Compliance: KPH]) Golan' (Signature) Kshitn Golan 9/25/2018 LATAMWERNATIONAL APPROVALS Client Facing Professional (CFP): (Signature) (Signature) Account Manager: Global Market Team Head (GMTH)/Sub- Market Team Head (SMTH): (Signature) AML Business Risk: AML ConViance: (Signature) (Signature) https://cfbrorcepb.my.salestorce.com.servIM. servlet Integration2lid=01N30000000D9Dr&eid=5000e00001NOBxm&ic=l&linkToken VmpF PSxNakF 4 41/42 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0066719 SDNY GM_00212903 EFTA01372830