EFTA01356815.pdf

RM Name Stewart Oldfield Business Line US Onshore GCIS # / KYC # 83290/ 01651789 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 account. If yes, please include relationship Total AUMs $224mn. since date. approx # of accounts. AUM. etc) Legal name of Account Zorro Management. LLC Holder(s) Name of UBO(s) Jeffrey Epstein (Please include U8Os 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 U8O) 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 (Y/N) 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 2 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042918 CONFIDENTIAL SDNY_GM_00189102 EFTA01356815