EFTA Document EFTA01399523

Cynthia Rodriguez From: Sent: To: Cc: Subject: Approved Sent from my BlackBerry 10 smartphone. From: Cynthia Rodriguez Sent: Thursday, December 15, 2016 11:43 AM To: Patrick Campion Cc: Armen Brash; Samantha Harmon Subject: RE: APPROVAL NEEDED: High Risk RUSH KYC Case 01696913 Hello, I am follow up on the below. Thanks for your help! Kind regards, Cynthia Rodriguez Patrick Campion Thursday, December 15, 2016 2:57 PM Cynthia Rodriguez Armen Brash; Samantha Harmon Re: APPROVAL NEEDED: High Risk RUSH KYC Case 01696913 Cynthia Rodriguez Assistant Vice President Deutsche Bank Trust Company Americas Deutsche Asset a Wealth Management 345 Park Avenue, 10154-0004 New York, NY, USA Tel. Fax Email From: Cynthia Rodriguez Sent: Wednesday, December 14, 2016 2:09 PM To: Patrick Campion Cc: Armen Brash; Samantha Harmon Subject: APPROVAL NEEDED: High Risk RUSH KYC Case 01696913 Importance: High Hello, I am requesting Exco Approval for Zorro Management, LLC, under the Jeffrey Epstein relationship. Mr. Epstein has recently created this U.S Virgin Islands entity, and would like to open a checking account before ye ar end. 1 EFTA01399523 RM Name Business Line GCIS ► / KYC New or Existing Relationship? If yes, please include relationahip since date, approx 4 of accounts, AUM, etc.) Legal name of Account Holder(s) Name of UBO(s) (Please include UBOs 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 UBO) Reason for High Risk 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 PEP (Y/N) If yes, include details Any negative media and/or court cases? Include ALL negative media 6 court cases 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 the relationship despite High Risk Factors All negative media and alerts have been reviewed by AML Compliance and they do not see a reason to discontinue the existing relationship with Jeffrey Epstein. Stewart Oldfield US Onshore 483290/ 01651789 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. Zorro Management, LLC Jeffrey Epstein We are opening checking account for new entity, Zorro Management LLC 2 EFTA01399524 Kind regards, Cynthia Rodriguez Cynthia Rodriguez Assistant Vice President Deutsche Bank Trust Company Americas Deutsche Asset a Wealth Management 345 Park Avenue, 10154-0004 New York, NY, USA Tel. Fax Email 3 EFTA01399525