EFTA Document EFTA01409534

Subject: RE: Epstein account openin [I] From: Vahe Stepanian Date: Mon, 01 Feb 2016 08:57:39 -0500 To: Daniel Sabba Cc: Ariane Dwyer Classification: For internal use only Updated per your request: Jeffrey E. Epstein was listed as initial president of Gratitude America Ltd, therefore, we wanted to make sure to go through the proper channels such that risk is mitigated from the bank's perspective. As per guidance from Wayne Salit (in AML) - the Southern Financial relationship can transac