EFTA01406210.pdf

Subject: Assistance re uired in resolving points - KYC #01977695 [I] From: Alka Babu Date: Wed, 24 Oct 2018 09:13:47 -0400 To: Bradley Gillin Richard Iarossi Cc: Vinita Advani Vijay-A Sawant Classification: For internal use only Hi Brad, We had a rejection for the captioned KYC for accounts The 2007 Jeffrey E. Epstein Insurance Trust #3, The Haze Trust, NES, LLC, Plan D, LLC We need your inputs on the points highlighted in red. Case #: 01977694 Relationship: SOUTHERN FINANCIAL RELATIONSHIP Customer Name: The 2007 Jeffrey E. Epstein Insurance Trust #3 Customer Number: 00000487199 Reason for Rejection:10/19/2018 - Rejection Points: 1. Please provide evidence of or a case comment regarding confirmation from the client that the information on the KYC is still accurate (i.e. ownership structure, signatories, etc. have not changed). The comment must include the name of the person spoken with and date this conversation occurred. (The attached internal email does not meet this requirement.) — Have attached the no material confirmation received by you for your reference, however we need more info as per the rejection point. 3. Andrew Gallivan's approval is not dated on the KYC. — Please advise Andrew Gallivan to input the approval date in the case. a. 5. The nature of business narrative for NES LLC states the entity was formed to take care of the expenses associated with running one of Jeffrey's homes. However, the KYC states the purpose of its DDA account is to pay for costs associated with Jeffrey's airplanes. Please review and EFTA01406210 ensure that information is consistent. I had taken the nature of business from the customer page of NES LLC which states "NES, LLC was formed to take care of the expenses associated with running one of Jeffrey Epstein's homes" and the purpose of the account that you had provided states "This is a simple checking account for pay for costs associated for Jeffrey Epstein's airplanes". Please assist us as this seems to be inconsistent by the checker. 6. The Haze Trust: f. Brokerage account: The signatories identified on the KYC are not consistent with the parties listed in NetX. Darren is the only individual tagged as a signatory on the KYC. Please ensure that the KYC is updated to include all authorized parties for the brokerage account and required information and documentation (including research). — Kindly provide this as we do not have access to NetX. 11. Plan D LLC: b. Nature of business: Please confirm. Equipment rental/- leasing is listed as the industry for this entity on the Dunn & Bradstreet report (within the due diligence searches). If this is accurate, the KYC should reflect this information. — We need your assistance on the accuracy on Customer page of Plan D LLC mentions "LLC created to hold funds to pay for costs associated with one of Jeffrey Epstein's planes" and search states "Equipment rental/leasing" in the SIC codes (research is attached for your quick reference) c. Please identify the legal reps and update the entity details page to reflect this information. The Operating Agreement states the company is manager-managed. An individual named Lawrence Visoski is identified as the initial manager. Is he still the manager of the company? Legal reps must be identified, verified, and added as parties to the KYC. Diligence searches are also required for legal reps. - We need your assistance on the status of Lawrence Visoski. Kind regards, fcid:1 [email protected] EFTA01406211 Alka Babu KYC Case Representative Deutsche CIB Centre Private Limited Deutsche Bank Group Wealth Management Bl, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway Goregaon East, Mumbai - 400063 , India EFTA01406212