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KYC Print Page 21 of 22
H. CMS Comments
Created By Date Comments
The KYC serves as a high pa< update tor the below listed cents (togetner taccounthoiders") -
I Southern Financial, LLC
2 Southern Trust Company, Inc
3 Jeffrey Epstein
4 J. Epstein Virgin Islands Foundation, Inc
Below are the reasons why we are comfortable with approving this KYC:
• Information and supporting documents required by our AML Policy were provided and
reviewed; and as a result, we have an understanding of the structure of the accountholders,
:heir purpose, the purpose of the accounts and expected transaction activity.
Kshitn Golan/ 818/117 4:45 PM • There are a few risk factors associated with the accountholders -
SOW: The U8Os (Jeffrey Epstein) is the founder of Southern Trust Company Inc. which
manages dents assets SOW verification was obtained.
Negative Media 8 PEP: There is some negative media against Mr Epstein and he is also
maintains a close relationship with Bill Clinton and Prince Andrew. Please see risk calculator for
more information. Appropriate approval was obtained.
• Our review did not identify any red flags and thus there was no need to escalate this case
further.
• We performed due diligence searches on all parties and did not find the names searched to De
on any sanctions lists
Verification of Address for Jeffrey Epstein is attached. it is his most recent paycheck from
Cynthia Rodriguez 7/71117 1:50 PM
Southern Trust Company Inc.
Cynthia Rodriguez 6:30i1I7 1:28 PM google searches for UBO can be found in KYC case 01790820
Cynthia Rodriguez 7171117 2:28 PM client confirmed no material changes on 07/0112017 vra phone
Cynthia Rodnguez 7/7/117 2:17 PM research for Jean Anne Brennan Weigel:lit is attached to kyc case 01790820
ONSHORE APPROVALS
Client Facing Professional (CFP) stewart oldfield (Signature) 7/5/2017
stewart afield
Office Director/Business Head Andrew F Gallivan (Signature) 7/6/2017
Andrew F Gallivan
Regional Off ce Director: (Signature)
AML Business Risk:
(Signature)
MIL Compliance:
(Signature)
Kshiti) Golan' Kshitij Golan' 818/2017
Yoonsun Chung Yoonsun Chung 8/8/2017
LATAM/INTERNATIONAL APPROVALS
Cent Facing Professona iCFoi (Signature)
Account Manager (Signature)
(Signature)
https://dbforcepb.my.salesforce.com/serylet/servlet.Integration?lid IN30000000D9Di&e... 1/11/2018
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0041473
CONFIDENTIAL SDNY_GM_00187657
EFTA01356047
ℹ️ Document Details
SHA-256
38d5bd99f5a0c9d2e71e8c8f0b8232f48e73cad50c1a8b77ab15feafd50ab5a7
Bates Number
EFTA01356047
Dataset
DataSet-10
Document Type
document
Pages
1
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