EFTA01372918.pdf

7/15/2019 KYC Print M. Case Comments Created By Date Comments Cynthia Rodriguez 9/6/117 12:05 AM recent research and google searches for Erika Kelerhals can be found in approved case 01790655. Cynthia Rodriguez 9/6/117 12:09 AM ID for Erika Kellerhals can be found in approved case 01344537 This KYC serves as a high risk update for the below listed clients (together "accountholders") - 1. The Haze Trust 2. Butterfly Trust 3. The 2007 Jeffrey E. Epstein Insurance Trust 43 Below are the reasons why we are comfortable with approving this KYC: • Information and supporting document required by our AML Policy were provided and reviewed; and as a result, we have an understanding of the structure of the accountholders, their purpose, the purpose of the accounts and expected transaction activity. KshrtO Golani 916/117 3:22 PM • There are a few risk factors associated with the accountholders - SOW: The U80 (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages clients assets. SOW verification was obtained. Negative Media & PEP: There is some negative media against Mr Epstein and he is also maintains a close -elationship with Bill Clinton and Prince Andrew. Please see risk cakulator for more information. Appropriate approval ,vas 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 be on any sanctions ists. No material changes confirmed by the client via phone on 08/22/2017. Cynthia Rodriguez 8; 24;117 5:25 PM No GBSA forms required as determination is already noted on the system. Beneficiaries are all added as parties with DOB, SSN/Passport as, address & IDs ONSHORE APPROVALS Client Facing Professional (CFP): Chuck Walker (Signature) 8/25/2017 Chuck Walker Office Director/Business Head: Steven Mattus (Signature) 8/29/2017 Steven Mattus Regional Office Director: (Signature) NIL Business Risk: (Signature) NIL Compliance: (Signature) Kshiti) Golani Karts) Golani 9/6/2017 Yoonsun Chung Yoonsun Chung 9/6/2017 LATAM/INTEFtNATIONAL APPROVALS Client Facing Professional (CFP): (Signature) Account Manager: (Signature) Global Market Team Head (Gl4TH):Sub. (Signature) Market Team Head (94TH): NIL Business Risk: (Signature) AML Compliance (Signature) httpe://dbforcepb.my.salesforce.comiservletserylet Integration?'id =0 I N 3000000009Di&eid=5003200001EHPpb&Ic=1&I nkToken=Vmp FP Sx Na k F4 T 42/43 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0066828 CONFIDENTIAL SDNY GM_00213012 EFTA01372918