EFTA Document EFTA01406993

Subject: RE: APPROVAL NEEDED: Hi h Risk KYC Case 01651789 [I] From: Patrick Campion Date: Fri, 14 Oct 2016 17:02:20 -0400 To: Cynthia Rodriguez Cc: Armen Brash Classification: For internal use only Approved. Just to be accurate, the client was presented to RRC and cleared. Kind regards, Patrick Campion {https://brandportal.intranet.db.com/img/modules/logo.gif} Patrick Campion Managing Director I Head of Wealth Management Americas Deutsche Bank Trust Company Americas Wealth Management - Americas 345 Park Avenue, 10154-0004 New York, NY, USA Tel. Mobile Email From: Cynthia Rodriguez Sent: Friday, October 14, 2016 4:43 PM To: Patrick Campion Cc: Armen Brash Subject: APPROVAL NEEDED: High Risk KYC Case 01651789 Hello, I am requesting Exco Approval for the Butterfly Trust, an existing trust here at DB, under the Jeffrey Epstein relationship. Mr. Epstein has replaced the beneficiaries to this trust, which is the reason for this KYC update. EFTA01406993 RM Name Stewart Oldfield Business Line US Onshore GCIS # / KYC # 483290/ 01651789 New or Existing Relationship? If yes, please include relationahip since date, approx # of accounts, AUM, etc.) 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. Legal name of Account Holder(s) Butterfly Trust Name of UBO(s) (Please include UBOs who own 25% and more; If there are multiple layers, please include description of ownership structure) Jeffrey Epstein Description of Type of account being opened with detailed purpose of the accounts (Please include SOW information/ Geographic location/ EFTA01406994 For Entity Accounts: Description of the entity and background information on the UBO We are updating the beneficiaries to this existing trust account where Jeffrey Epstein is the grantor. 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 No Any negative media and/or court cases? Include ALL negative media & court cases 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. EFTA01406995 Kind regards, Cynthia Rodriguez fcid:[email protected] Cynthia Rodriguez Assistant Vice President Deutsche Deutsche 345 Park Tel. Fax Email Bank Trust Company Americas Asset & Wealth Management Avenue, 10154-0004 New York, NY, USA EFTA01406996