EFTA01356213.pdf

KYC Print Page 21 of 22 H. CMS Comments Created By Date Comments The KM serves as a high war update tor the below listed cents (togenter taccountho!ders") - I Southern Financet, LLC 2 Southern Trust Company, Inc 3 Jeffrey Epstein 4 J. Epstein Virgin Islands Foundation, Inc Below are the reasons why we are comfortable with approving this KYC: • Information and supporting documents required by our AML Policy were provided and reviewed; and as a result, we have an understanding of the structure of the accountholders, :heir purpose, the purpose of the accounts and expected transaction activity. Kshitij Golan/ 818/117 4:45 PM • There are a few risk factors associated with the accountholders - SOW: The U8Os (Jeffrey Epstein) is the founder of Southern Trust Company Inc. which manages clients assets SOW verification was obtained. Negative Media 8 PEP: There is some negative media against Mr Epstein and he is also maintains a close relationship with Bill Clinton and Prince Andrew. Please see risk calculator for more information. Appropriate approval was 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 De on any sanctions lists Verification of Address for Jeffrey Epstein is attached. it is his most recent paycheck from Cynthia Rodriguez 7/71117 1:50 PM Southern Trust Company Inc. Cynthia Rodriguez 6;30/117 1:28 PM google searches for UBO can be found in KYC case Cynthia Rodriguez 717/117 2:28 PM client confirmed no material changes on 07/01/2017 via phone Cynthia Rodnguez 7/7/117 2:17 PM research for Jean Anne Brennan Weigel:lit is attached to kyc case ONSHORE APPROVALS Client Facing Professional (CFP) s:ewart oldfield (Signature) 7/5/2017 stewart afield Office Director/Business Head Andrew F Gallivan (Signature) 7/6/2017 Andrew F Gallivan Regional Office Director: (Signature) AML Business Risk: (Signature) MIL Compliance: (Signature) Kshiti) Golan' Kshitij Golan' 818/2017 Yoonsun Chung Yoonsun Chung 818/2017 LATAM/INTERNATIONAL APPROVALS Gent Facing Professona iCFai (Signature) Account Manager (Signature) (Signature) https://dbforcepb.my.salesforce.com/serylet/servlet.Integration?lid IN30000000D9Di&e... 1/11/2018 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0041930 CONFIDENTIAL SDNY_GM_00188114 EFTA01356213