EFTA Document EFTA01408957

Subject: RE: RUSH EXCO Approval Needed: KYC Case 01898372 [I] From: Cynthia Rodriguez Date: Mon, 12 Feb 20 To: Patrick Campion Cc: Dana Ponzio Classification: For internal use only Hi Patrick, I am following up on the below. Thanks! Kind regards, Cynthia Rodriguez {cid:[email protected]} Cynthia Rodriguez Assistant Vice President Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 rk Av n 24t Fl 1 Tel. Fax Emai From: Cynthia Rodriguez Sent: Friday, Februar To: Patrick Campj Cc: Dana Ponzio Subject: RUSH EXCO Approval Needed: KYC Case 01898372 [I] Importance: High w York, NY, USA EFTA01408957 Classification: For internal use only Hello, I am requesting Exco Approval for a new account opening for current DB client Jeffrey Epstein. RM Name Stewart Oldfield Business Line US Onshore GCIS # / KYC # 575969/ 01898372 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 30 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) The 2017 Caterpillar Trust Name of UBO(s) EFTA01408958 (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/ For Entity Accounts: Description of the entity and background information on the UBO) We are opening a deposit account for The 2017 Caterpillar Trust. The account will be used to pay annual annuity payments 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 Yes, close affiliation to Bill Clinton and Prince Andrew 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 EFTA01408959 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. Kind regards, Cynthia Rodriguez {cid:[email protected]} Cynthia Rodriguez Assistant Vice President Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 Park Avenue, 24th Fl 10154-0004 New York, NY, USA Tel Fax Ema EFTA01408960