EFTA01255153.pdf

Cynthia Rodriguez From: Patrick Campion Sent: Thursday, December 15, 2016 2:57 PM To: Cynthia Rodriguez Cc: Armen Brash; Samantha Harmon Subject: Re: APPROVAL NEEDED: High Risk RUSH KYC Case Approved Sent from my BlackBerry 10 smartphone. From: Cynthia Rodriguez Sent: Thursday, December 15, 2016 11:43 AM To: Patrick Campion Cc: Armen Brash; Samantha Harmon Subject: RE: APPROVAL NEEDED: High Risk RUSH KYC Case Hello, l am follow up on the below. Thanks for your help! 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. Fax Em From: Cynthia Rodriguez Sent: Wednesday, December 14, 2016 2:09 PM To: Patrick Campion Cc: Armen Brash; Samantha Harmon Subject: APPROVAL NEEDED: High Risk RUSH KYC Case Importance: High Hello, I am requesting Exco Approval for Zorro Management, LLC, under the Jeffrey Epstein relationship. Mr. Epstein has recently created this U.S Virgin Islands entity, and would like to open a checking account before year end. 1 SDNY_GM_00057470 CONFIDENTIAL — PURSUANT TO FED. R.QQN(F IDENTIAL DB-SDNY-0020294 EFTA_00I 68038 EFTA01255153  RM Name Stewart Oldfield Business Line US Onshore GCIS # / KYC # New or Existing Existing relationship since B/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, AIM. etc) Legal name of Account Zorro Management, LLC Holder(s) Name of UBO(s) Jeffrey Epstein (Please include UBOs 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 UBO) 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 II yes. include details Any negative media Yes and/or court cases? lncluo'e ALL negative media S 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 SDNY_GM_00057471 CONFIDENTIAL - PURSUANT TO FED. R.CON(F IDENTIAL DB-SONY-0020295 EFTA_OOI 68039 EFTA01255154  Kind regards, Cynthia Rodriguez Cynthia Rodriguez Assistant Vice President Deutsche Bank Trust Company Americas Deutsche Asset E. Wealth Management 345 Park Avenue, 10154-0004 New York, NY. USA Tel Fax Em 3 SDNY_GM_00057472 CONFIDENTIAL — PURSUANT TO FED R.QP.NEIDENTIAL DB-SDNY-0020296 EFTA_00168040 EFTA01255155