EFTA01364196.pdf

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 U80) 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 PEP (YIN) No If yes. include details Any negative media Yes and/or court cases? Include ALL negative media 8 court cases If Yes, please give details Aside from the court cases listed in the reason for high risk, all other alerts were false positives and no new court cases or negative media has come up for this client. Business Justification All negative media and alerts have been reviewed by AML Compliance and they do for the relationship not see a reason to discontinue the existing relationship with Jeffrey Epstein. despite High Risk Factors Kind regards. Cynthia Rodriguez Cynthia Rodriguez Assistant Vice President Deutsche Bank Trust Company Americas Deutsche Asset & Wealth Management 345 Park Avenue 10154-0004 New York. NY. USA Tel. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0054722 CONFIDENTIAL SDNY_GM_00200906 EFTA01364196