EFTA Document EFTA01385146

Business Line US Onshore GCIS # / KYC # New or Existing Relationship? If yes. please include relationahip since date. approx tl of accounts. AUM. etc.) Legal name of Account Holder(s) Name of UBO(s) (Please include UElOs 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 IRO) Reason for High Risk PEP (Y/N) If yes. include details Any negative media and/or court cases? Include ALL negative media court cases If Yes, please give details Business Justification for the relationship despite High Risk Factors 575969/01898372 Existing relationship since 8/26/2013. A total of 30 deposit accounts and 3 mon market accounts for multiple entities, 5 brokerage accounts and 1 custody acct Total AUMs $224mn. The 2017 Caterpillar Trust Jeffrey Epstein We are opening a deposit account for The 2017 Caterpillar Trust. The account • used to pay annual annuity payments This relationship is deemed high risk due to multiple court cases on Jeffrey Eps involving 22 April 2004 SEC filed a settled civil fraud action for illegal insider tra three publicly traded Massachusetts banks. Final judgement permanently enjoii from violating the antifruad provisions and he agreed to pay a total of $72532.0£ disgorgement of trading profits, prejudgment interest and civil penalties. Epsteir sentenced to 21 months in federal prison for three counts of fraud, sexually ass a girl and solicitation of prostitution. These alerts were previously approved by management and AML Compliance. Prior clearance is attached as a reference Yes, close affiliation to Bill Clinton and Prince Andrew Yes Aside from the court cases listed in the reason for high risk, all other alerts were positives and no new court cases or negative media has come up for this client All negative media and alerts have been reviewed by AML Compliance and the not see a reason to discontinue the existing relationship with Jeffrey Epstein. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0086237 CONFIDENTIAL SDNY_GM_00232421 EFTA01385146