EFTA Document EFTA01437353

Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# N4G024943, Alert# SAM1788880 [I] From: Vahe Stepanian Date: Tue, 20 Dec 2016 10:09:26 -0500 To: Amlcompliance In uiries Zbynek Kozelsky Cynthia Rodrigue PWM AMLComplianc Stewart Oldfie Cc: Joshua Shoshan Donald Summer Cherie Quigley Classification: For internal use only We don't know the answer. Are we supposed to reach out to client about this? Thanks, Vahe From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Tuesday, December 20, 2016 9:39 AM To: Zbynek Kozelsky; Cynthia Rodriguez; PWM AMLCompliance; Stewart Oldfield; Vahe Stepanian Cc: Joshua Shoshan; Donald Summer; Cherie Quigley; Amlcompliance Inquiries Subject: RE: UR D REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I] Importance: High Classification: For internal use only Good Morning: From the initial response below, it appears that a response was given on a different wire in the amount of $23 mil between brokerage and the private bank. Can anyone answer the inquiry regarding the wire from HSBC? EFTA01437353 {cid:[email protected]} Incoming: 10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION 1. Who is the ultimate originator of these funds (i.e. if this is investment income, please give the name of the investment that the funds originate)? Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York. NY 10005 - 2836 ax: From: Zbynek Kozelsky Sent: Tuesday, December 20, 2016 8:34 AM To: C nthia Rodri uez PWM AMLCom liance Stewart 0 dfie d ; Vahe > Cc: Joshua Shoshan ; Donald Summer Amlcompliance Inquiries Subject: RE: UR TRUST, Account# : nquiry •egarding THE HAZE Alert# SAM1788880 [I] Classification: For internal use only Dear AML, EFTA01437354 Please let us know what else you need regarding this HSBC wire so we close the loop. Happy holidays. Ziggy fcid:[email protected] Zbynek "Ziggy" Kozelsky Director I Branch Administrative Manager Key Client Partners - Americas Deutsche Bank Securities Inc. Deutsche Asset & Wealth Management 345 Park Avenue, 26th Floor New Y Tel. Email: All trade execution information contained herein is being provided as an accommodation at your request in advance of your receipt of the official trade confirmation(s). Additional trade detail information available upon request. The terms of the trade(s) may be subject to change prior to settlement, and therefore the official trade confirmation(s) and account statements issued by Deutsche Bank shall govern. Deutsche Bank is not responsible for any discrepancy between the informal execution report and the official trade confirmation(s) or account statements. This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received this email in error), please notify the sender immediately and delete the email from your computer. Any unauthorized copying, disclosure or distribution of the material in this email is prohibited. EFTA01437355 From: Cynthia Rodriguez Sent: Tuesday, December 20, 2016 8:32 AM To: PWM AMLCompliance; Zbynek Kozelsky; Stewart Oldfield; Vahe Stepanian Cc: Joshua Shoshan; Donald Summer; Cherie Quigley; Amlcompliance Inquiries Subject: RE: UR D REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I] Vahe/Donald/Ziggy, Do you need anything from Stew and I for the below request? We provided as much information as we could, but the transaction in question came into the brokerage account from HSBC and not from the private bank. Let us know if you need anything from us in order to complete the below. Thanks! 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 Tel Fax Email EFTA01437356 From: Danya Friedman On Behalf Of PWM AMLCompliance Sent: Tuesday, December 20, 2016 8:01 AM To: Cynthia Rodriguez; Zbynek Kozelsky; Stewart Oldfield; Vahe Stepanian Cc: Joshua Shoshan; Donald Summer; Cherie Quigley; Amlcompliance Inquiries Subject: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I] Importance: Classification: For internal use only Good Morning: I am writing to follow up on the inquiry below. Please note that this is the 3rd request for information. Please respond ASAP. Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York, NY 10005 - 2836 Fax: From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Wednesday, December 14 2016 8: To: C nthia Rodriguez ; Zb nek Kozelsk Stepanian O I It 1.1 - • hl Stewart Oldfield Cherie comp lance nquiries Subject: RE: Inquiry Rega SAM1788880 [I] Importance: High r • ing Ul le ; Vahe loo. $ HU' , 'ccoun Alert# rn EFTA01437357 Classification: For internal use only Good Morning: I am writing to follow up on my inquiry below. Thank you. Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York. NY 10005 - 2836 Fax: From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Monday, December 05, 2016 12:05 PM To: C nthia Rodri•uez • Zb nek Kozelsk ewar ie ; Vahe Stepanian • ; Donald Summer erie uui• ey Amlcompliance Inquiries Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# SAM1788880 [I] Importance: High Classification: For internal use only Thank you for the response Cynthia. Alert# Team, this is not the wire I am asking about. Please see the incoming wire listed below from HSBC. I see the $23,000,000.00 incoming wire from the Private Bank account and that is not/was never in question. I need to know EFTA01437358 where these funds originate. 10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York NY 10005 - 2836 ax: {cid:[email protected]} From: Cynthia Rodriguez Sent: Monday, December 05, 2016 11:32 AM To: Amlcompliance Inquiries ; Zbynek Kozelsk ; Stewart Oldfield Cc: Joshua Shoshan ; Donald Summer Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I] All, 11. The originating wire came f ient's account called Southern Trust Company, Inc account number This wire was not submitted through HSBC but through Bank of New or 0 in order to be placed into their N4G account for the art purchase. The beneficiary is our client Jeffery Epstein as the originating party and the art purchaser. Please let me know if you need anything else. Kind regards, EFTA01437359 Cynthia Rodriguez fcid:[email protected] Cynthia Rodriguez Assistant Vice President Deutsche Bank Trust Company Americas Deutsche Asset & Wealth Management 345 Park Avoniio ini54-0004 New York, NY, USA Tel. Fax Email From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Friday, December 02, 2016 11:36 AM To: Zbynek Kozelsky; Amlcompliance Inquiries; Stewart Oldfield; Vahe Stepanian Cc: Joshua Shoshan; Donald Summer; Cynthia Rodriguez Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I] Classification: For internal use only Please specify the originating account so that I can confirm this transaction, after searching PRIME and DB FORCE (our PB systems, I am unable to locate the transaction). Also, any idea as to why, if this is an internal transfer, that funds are being sent through HSBC? Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York NY 10005 - 2836 Fax: EFTA01437360 From: Zbynek Kozelsky Sent: Friday, December 02, 290112maihtAli To: Amlcompliance Inquiries e • Stewart Oldfield Vahe Stepanian Cc: Joshua Shoshan < Donald Summer Cynthia Rodriguez Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# N4G024943, Alert# SAM1788880 [I] Classification: For internal use only Just to clarify, the funds came in from client's Private bank account (in house — from DBTCA account/PB into his DBSI account). Thanks {cid:[email protected]} Zbynek "Ziggy" Kozelsky Director I Branch Administrative Manager Key Client Partners - Americas Deutsche Bank Securities Inc. Deutsche Asset & Wealth Management 345 Park Avenue, 26th Floor New Tel. Emai All trade execution information contained herein is being provided as an accommodation at your request in advance of your receipt of the official trade confirmation(s). Additional trade detail information available upon request. The terms of the trade(s) may be subject to change prior to settlement, and therefore the official trade confirmation(s) and account EFTA01437361 statements issued by Deutsche Bank shall govern. Deutsche Bank is not responsible for any discrepancy between the informal execution report and the official trade confirmation(s) or account statements. This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received this email in error), please notify the sender immediately and delete the email from your computer. Any unauthorized copying, disclosure or distribution of the material in this email is prohibited. From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Friday, December 02, 2016 11:21 AM To: Stewart Oldfield; Vahe Stepanian; Zbynek Kozelsky; Amlcompliance Inquiries Cc: Joshua Shoshan; Donald Summer; Cynthia Rodriguez Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# N4G024943, Alert# SAM1788880 [I] Classification: For internal use only Good Morning and thank you for the quick response. Just to clarify, the below response is only answering my questions regarding the Outgoing Transfers and both of these transfers were towards the purchase of art? We will need the ultimate originator for the Incoming Transfer. Also, once again, just to clarify, we have the KYC on the HAZE TRUST, we need the source of wealth for the beneficiaries if available. Thanks again! I hope everyone has a great weekend! Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York, NY 10005 - 2836 Fax: EFTA01437362 From: Stewart Oldfield Sent: Friday, December 02, 2016 11:17 AM • ; Zbynek Kozelsky pliance Inquiries Donald Summer Cynthia Rodriguez Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# SAM1788880 [I] Classification: For internal use only Cynthia is back Monday and will send all of the docs then. Thanks From: Vahe Stepanian Sent: Friday, December 02, 2016 11:11 AM To: Zbynek Kozelsky; Amlcompliance Inquiries Cc: Joshua Shoshan; Donald Summer; Stewart Oldfield Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# SAM1788880 [I] Classification: For internal use only Alert# Alert# Adding Stewart Oldfield, primary relationship manager who can confirm the below. 1. What is the purpose of the Outgoing Transfer? Purchase of Art. 2. What is the relationship between Beneficiary and Client? EFTA01437363 Per our conversation with client — the beneficiary in this situation is an escrow account in which the cash will be held until art is delivered. 3. Please provide the source of wealth for these entities. Stewart — can you please add here the Private Bank KYC, which I believe includes the SOW for this client? Thank you. Best, Vahe From: Zbynek Kozelsky Sent: Friday, December 02, 2016 11:03 AM To: Amlcompliance Inquiries Cc: Vahe Stepanian; Daniel Sabba; Joshua Shoshan; Donald Summer Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# SAM1788880 [I] Classification: For internal use only Vahe, Please follow up. Reason — purchase of art. Thanks Alert# EFTA01437364 fcid:[email protected] Zbynek "Ziggy" Kozelsky Director I Branch Administrative Manager Key Client Partners - Americas Deutsche Bank Securities Inc. Deutsche Asset & Wealth Management 345 Park Avenue, 26th Floor New York NY 10154 Tel. Email: All trade execution information contained herein is being provided as an accommodation at your request in advance of your receipt of the official trade confirmation(s). Additional trade detail information available upon request. The terms of the trade(s) may be subject to change prior to settlement, and therefore the official trade confirmation(s) and account statements issued by Deutsche Bank shall govern. Deutsche Bank is not responsible for any discrepancy between the informal execution report and the official trade confirmation(s) or account statements. This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received this email in error), please notify the sender immediately and delete the email from your computer. Any unauthorized copying, disclosure or distribution of the material in this email is prohibited. From: Danya Friedman On Behalf Of Amlcompliance Inquiries Sent: Friday, December 02, 2016 11:01 AM To: Zbynek Kozelsky Cc: Dcarla Oliveira; Tatiana Dominguez; Maurice Abitbol; Amlcompliance Inquiries Subject: Inquiry Regarding THE HAZE TRUST, Account# N4G024943, Alert# SAM1788880 [I] EFTA01437365 Classification: For internal use only Good Morning: As a part of the anti-money laundering monitoring program, the Actimize system is used to automatically identify transactions that meet certain high risk transaction patterns. When transactions occur which mimic those patterns, the activity must be researched to confirm that it is legitimate. In a small percentage of these cases, Compliance must contact the Wealth Advisor for additional information about the transaction(s) in order to conclude the research process. Your response is required for the Bank to comply with federal guidelines for concluding the research of these matters in a timely fashion. Your complete response must be received within 7 business days. To the best of your ability, please provide details regarding the item(s) below: Incoming: 10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION 1. Who is the ultimate originator of these funds (i.e. if this is investment income, please give the name of the investment that the funds originate)? Outgoing: 11/23/2016, $25,000,000.00, AP NARROWS HOLDING LP/BMO TRUSTEE at CDEC EFTA01437366 CLEARING ACCOUNT through BANK OF AMERICA, N.A., NY 11/23/2016, $5,000,000.00, LDB 2011 LLC/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA, N.A., NY 1. What is the purpose of the Outgoing Transfer? 2. What is the relationship between Beneficiary and Client? 3. Please provide the source of wealth for these entities. Thank you in advance for your prompt attention to this matter. Best Regards/Mit freundlichen GrOgen, PWM AML Compliance Deutsche Bank 60 Wall St., 23 Floor New York NY 10005 - 2836 ax: PLEASE NOTE: YOU ARE BEING CONTACTED BECAUSE YOU ARE LISTED AS THE PRIMARY OFFICER FOR THIS ACCOUNT ON GCIS. IF YOU ARE NOT THE CURRENT PRIMARY OFFICER, PLEASE LET ME KNOW IMMEDIATELY, SO THAT I MAY FORWARD THIS EMAIL TO THE APPROPRIATE PARTY. Do not forward this e-mail or any attachment directly to the client. EFTA01437367