EFTA01356281.pdf

Cynthia Rodriguez Assistant Vice PreNdent Deutsche Bank Trust Company Americas Deutsche Asset Si Wealth Management 345 P r 10154-CO04 New York. NY. USA Tel. Fax it 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 ICYC Case 01696913 Importance: High Hello, lam 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 # New or Existing Existing relationship since 8/26/2013. A total of 21 deposit accounts and 3 money Relationship? market accounts for multiple entities, 5 brokerage accounts and 1 custody If yes. please include relationship account. Total AUMs $224mn. since date. approx It of accounts. AUM. etc.) Legal name of Account Zorro Management, LLC Holder(s) Name of UBO(s) Jeffrey Epstein (Please include UBOs who own 25% and more; If there are multiple layers. please include description of ownership structure) Description of Type of We are opening checking account for new entity, Zorro Management LLC 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) 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 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042071 CONFIDENTIAL SDNY_GM_00188255 EFTA01356281