EFTA Document EFTA01409180

Subject: RE: APPROVAL NEEDED: Hi h Risk RUSH KYC Case 01696913 From: Cynthia Rodriguez Date: Thu, 15 Dec 2016 11:43:52 -0500 To: Patrick Campion Cc: Armen Brash Samantha Harmon Hello, I am follow up on the below. Thanks for your help! Kind regards, Cynthia Rodriguez {cid:[email protected]} Cynthia Rodriguez Assistant Vice President Deutsche Bank Trust Company Americas Deutsche Asset & Wealth Management 345 Park Avenue, 10154-0004 New York, NY, USA 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 EFTA01409180 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 year end. 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) Zorro Management, LLC Name of UBO(s) (Please include UBOs who own 25% and more; If there are multiple layers, please include description of ownership structure) EFTA01409181 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 U60) We are opening checking account for new entity, Zorro Management LLC 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. EFTA01409182 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 Asset & Wealth Management 345 Park Avenue, 10154-0004 New York, NY, USA Email EFTA01409183