EFTA Document EFTA01401231

Classification: For internal use only Hi Amanda, Please find the below approved clearance for Kind regards, Andrew Kisz Andrew Kisz Associate I AML Compliance Officer DB Services New Jersey, Inc. Asset a Wealth Management 5022 Gate Parkwa Suite 400, 32256 Jacksonville, USA Tel. orwar e y n rew Kisz/db,•n 12/04/2013 01:58 PM ----From: Jacqueline Lightbody/db/dbcom To: Cc: Date: Subject: Andrew Kisz/db PWMUS 12/04/2013 01:45 PM Re: Classification —THEEFFES—ilse only Hi Andrew, In reviewing the alert against and the previous attached approval by senior management for Jeffrey Epstein, I agree with your assessment . This alert can be cleared. I also recommend that the relationship be marked as "High Risk" to be consistent with the existing relationship with Jeffrey E pstein. Thanks. Kind regards, Jacqueline Lightbody Jacqueline Lightbody EFTA01401231 Vice President I AML Compliance Officer Deutsche Bank Trust Company Americas PWM AML Compliance 23rd Floor 60 Wall Street 10005-2836 New York, NY, USA Tel. Fax + Email From: To: Cc: Date: Subject: PWMUS AMLKYC/db/dbcom Jacqueline Lightbod /db/ PWMUS AMLKYC/db 12/03/2013 12:18 PM Classification: For internal use only Hi Jackie, This is an escalation for negative media pertaining to is a beneficiary of a trust wherein Jeffrey Epstein is the grantor. According to the business, is not opening an account and has no authority on the trust account. The alert involves allegations against II of being a co-conspirator of several federal offenses. The same offenses resulted in Jeffrey Epstein be ing sent to jail, but the charges against were dropped. The on-boarding of Jeffrey Epstein was previously cleared by Chip Packard (see attached) and subsequently cleared by AML Compliance based on that fact. Accordingly, AML Compliance is comfortable clearing this alert for the following reaso ns: 1) The account is already marked as high risk; 2) Chip Packard has reviewed and approved the on-boardin g of the relationship with Jeffrey Epstein and obtained clearance from a reputational and AML risk perspective. Jeffrey Epstein Clearance.pd£ From: To: Date: Subject: PWMUS AMLKYC/db/dbcom Jacqueline Lightbody/db/ 10/09/2013 05:53 PM DRAFT: [I] Classification: For internal use only Kind regards, Andrew Kisz Chip approval.pdf Andrew Kisz Associate I AML Compliance Officer DB Services New Jersey, Inc. Asset a Wealth Management EFTA01401232 5022 Gate Parkwa Suite 400, 32256 Jacksonville, USA Tel. From: To: Cc: Date: Subject: Amanda Kirby/db/dbcom PWMUS AMLKYC/db Andrew Kisz/db/ PWMUS AMLKYC/db/ 10/09/2013 04:50 PM Re: Fw: RDC ALERT - (I) Classification: For internal use only Hi Andrew, This is part of the Jeffrey Epstein relationship. She is named as one of the beneficiaries of a trus t that he is the Grantor of (Butterfly Trust). She is not opening an account and has no authority on the trust account Best, Amanda Kirby Amanda Kirby Associate Deutsche Bank Trust Company Americas 345 Park Avenue, 27th Fl New York NY USA 10154-0004 From: To: Cc: Date: Subject: PWMUS AMLKYC/db/dbcom Amanda Kirby/db PWMUS AMLKYC/db 10/09/2013 04:44 PM Re: Fw: RDC ALERT - (I) Classification: For internal use only Hi Amanda, Is this part of the Jeffrey Epstein relationship or is opening a new account? Kind regards, Andrew Kisz EFTA01401233 Andrew Kisz Associate I AML Compliance Officer DB Services New Jersey, Inc. Asset a Wealth Management 5022 Gate Parkwa Suite Tel. From: 400, 32256 Jacksonville, USA To: Cc: Date: Subject: Amanda Kirby/db/dbcom PWMUS AMLKYC/db Michael Vila/db Andrew Kisz/db/ Andrea Klingenberg/db/ 10/08/2013 01:29 PM Fw: RDC ALERT - Classification: For internal use only Hi, The attached alert does pertain to our client. was accused as a co-conspirator in a cas e but was never brought to trial nor ever convicted. She will also never have her own personal account her e at DB. The account for which she will be associated is a trust account which names her as a beneficiary She will have no authority over this account and will not be a client of the bank. Please clear this alert or let me know if you require further information (i.e. trust agreement) Best, Amanda Kirby ( I ) Amanda Kirby Associate Deutsche Bank Trust Company Americas 345 Park Avenue, 27th Fl New York NY USA 10154-0004 Forwarded by Amanda Kirby/db/dbcom on 10/08/2013 01:25 PM ---- EFTA01401234 From: To: Cc: Date: Subject: ?WM BIS-Research/db/ PWMUS AMLKYC/db 10/07/2013 03:52 PM RDC ALERT - [I) Classification: For internal use only Hello, Attached is an alert for the party mentioned above. Please note that clearance from compliance is required prior to KYC approval. Please follow the instructions below: Forward explanation of whether the alert pertains to your client directly to compliance. Receive confirmation from compliance that alert can be removed from the queue. Include copies of all res onses along with your KYC. lattachment • Alert l.pdf" deleted by Amanda Kirby/db/dbcom) [attachment "- Alert. df" deleted by Amanda Kirby/db/dbtom] (attachment • Alert l.pdf" deleted by Jacqueline Lightbody/db/dbcom) [attachment • Alert.pdf• deleted by Jacqueline Lightbody/db/dbcom] Thanks, Ahsan Manzoor EFTA01401235