EFTA Document EFTA01420255

Subject: FW: RUSH EXCO Approval Needed: KYC Case 01898372 [I] From: Dana Ponzio ‹ > Date: Wed, 14 Mar 2018 11:43:32 -0400 To: Stewart Oldfield ‹ > Classification: For internal use only Hi-This is the approval you were asking about yesterday? Kind Regards, Dana Ponzio {https://brandportal.intranet.db.com/img/modules/logo.gif} Dana Ponzio Executive Assistant to Patrick Campion and Sheffali Welch Deutsche Bank Trust Company Americas US Private Wealth Management 345 Park Avenue, 24th Floor New York, NY, 10154 Tel. Fax • Mobile Email EFTA01420255 From: Cynthia Rodriguez Sent: Friday, February 09, 2018 3:18 PM To: Patrick Campion Cc: Dana Ponzio Subject: RUSH EXCO Approval Needed: Importance: High KYC Case 01898372 [I] 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. EFTA01420256 Legal name of Account Holder(s) The 2017 Caterpillar Trust Name of UB0(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/ 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 EFTA01420257 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. 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 Email EFTA01420258