EFTA01282185.pdf

KYC l'rint Pagel of 10 DB PWM GLOBAL KYC/NCA: PART A KYC Case * : 01898372 Status : 6. Approved One sheet must be established per relationship- list all accounts included in the relationshi 1. Relationship Details Relationship Name: SOUTHERN FINANCIAL RELATIONSHIP:00000483290 Boddng Center: New York Relationship Manager: Stevan Oldridd O New PPM Reladonship O eating Meal Relationship Relationship to PM: If caisdrg, please indicate axe when the !deanship oasts, provide reason for new profile and attach old wade: Initial funding must take place by 02/13/2018 In order to pachase assets for the trust 0 Gent Referral O RM Prospect O Intermediary/FIN O Other Source (OS, etc) How Was the Clangs) Introduced? How bang has the Please provide details (e.g. name of referral son, new many years RM person.* has known dent, etc.): Jeffrey Epstein reamed RM personally known the client? out to Stew CliclAdd x12/02/2018 to open a new deposit account for Ns annuity trust. Intel fielding must take state by 02/13/2018 in order to purchase assets for the trust Does Deutsche Earle pay a O yes I IA No rehear:slat or singer compensation to a third party for the introduction of this (If Ve5 cksate) relationshp? List di existing and new accounts Invoked in this relatbnalp Legal Enay Account Name 1minter opening Date (Intended/actual) AccouM(s) 1 D The 2017 Caterpitar Trust . Deposit 2/13/2018 Who is the primary muted person a the RH? (Note: TVs , Preferred method 01 contact person needs to nave soatory (indicate phone ro., fax no., right and/or Information right email address, etc.): for the accounts.): SDNY_GM_00037476 CONFIDENTIAL - PURSUANT TO FED. R. Ce I ONFIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... 7/11/2019 DB-SONY-0000300 EFTA_00148088 EFTA01282185  KYC Print Page 2 of 10 One sheet must be established for each account to be opened 2. Account Ownership Summary Account Name: The 2017 Caterpillar Trust - Deposit Acct. Minter tifoludablet. Account Manager: stenett oldfield What is the purpose of the account (e.g. prmfdlo management, advisory aocouit, custody senaces, long-term Investment. paymentlesPerde amount)? the Purpose of this account k to hold the member Interest in IGO Company LLC Indicate from where the assets are expected to arrive? GO Group: Same Stoking Center (indicate account number): 3526%91 O GO Group: Other Booting Center (indicate GO location and account details): O Other Ins/Motion - (lndkate name & location): O Physical Deposits (spedfy cash, securities, cheques....): What is the expected size and frequency of regular inflows and outflows for the account (Indicate estimated number and yolune per month)?: less than 2 dstrituticns on an annual basis between $0 and $100k 1 300000 I Currency I usd What is the expected volume of assets and currency for the account approx. 90 days alter opening? 1300000 I Currency I usd what is the expected volume of assets and currency for the account approx. one year after opening? Does/will the client have Assets Under Management (AuM) within DC under arr. 3M? OYes 0 No Please list all parties related to the account. For each party: • Check d a source of wealth description is required for the party. • Check the appropriate box to describe the relabonshp of the party to this account (> 1 can be selected). • I none of the check bco2s appty, describe the palls elation to the account in the "Other column. • Always describe the relation hp between the parties I the last column. • Please WI down to the ubmatejundedying Benefidal Owner(s) egS DescrOUNI AccormtP1C SetUor of Ultimate SignalogyLimrtedFinandal Significant _egal Granter/Settlorfouiding Enthral Source Holder Omer/Trust / Benefidelor Full POA IntermediarySharenokleriztepresentaUye Dona of Wealth Founder of Owner POA :FIM) K>=25%) equired Foundation hbn.PiC Other (please Parties entity describe other roles related to (indicate and/or indicate this ownership relationship account %) between parties) The 1 El 0 2°17 Caterpillar 21 O O O O O O O O O Trust Beneficiary:Grantor and Benefidary of The 2017 2 O 2 ' emel t Epstein O O 2 O O O O O O O cater oar Trust.;Grantor of The 2013 Butterfly Trust; 3 O O "Kei Daphne l: OO O EJ O O O O O Trustee:;Uustee; 4 O O .OOO O Ei O O O O O trustee; Trustee:: CONFIDENTIAL - PURSUANT TO FED. R. t I ONFIDENTIAL SDNY_GM_00037477 DB-SONY-0000301 https://dbforcepb.my.salesforce.com/servlet/servlet.lntegration?lid=01N30000000D9Di&e... 7/11/2019 EFTA_00148089 EFTA01282186  KYC l'rint Page 3 of 10 One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa 3A. Individual Details (Mg all panes) Indlviduars Name: Jeffrey E. Epsten - Date d Birth: 1120//953 Country of Residence: USVI Country of Otizenship: USA Has client resided outside d Utte Sant James Saint Thomas 00802 United States Ns/her country of nationalty for ID yes IS No Address of primary residence: 5 years or more? Profession/Oxupation: Self Empolyed Tax ID / SSN: Cur-rent Employer: Southern Trust Company LLC PositkrVTIVORank: President Address of employer: 6100 Red Hook Quarter B3 St. Thomas United States 00802 Does the person work as senior executive of a DB-recognized regulated entity in the financial ndustry? or an edgy aged on a DB-recognised exchange? (Not applicable for operating entities • Ts Ea No Is the indteidual a Politically Exposed Person (PEP)7(1Y Yet deznbe) connection with Prince Andreve 2 yes O No and 611 Clinton To the best of you knowledge. Is the Vidividual !Sated to an employee of the DB group?&Fandy or O Family O Men:Islip ElNone Frieruthip, ciesothe) To the best of your knowledge, is the IndNiduS party to a non-banking relationship wth Deutsche o yes 2 No Bank (e.g., external legal counsel, client referral sows, supplierof goods or seNices)?(if YesYea-etc ) Indicate where and when the client meeting(s) took place: If applicable, Indicate which bank officers have nice the person: Client Private Crient Place of Bank Officer Names) Bank Of Other Location (specify): Date: Domicile: Business: O O O O O O O O O O Wealth Details for this Individual are not fled in, because they are the same as for the following person: 38. Wealth Details (Only for parties requiring soLece of wealth description as indicated in Section 2) Nature of the Individual's Business: Prhete investments Winery Country of source of weSM/source d Funds? Primary industry of solace of WeaUVSource at Funds? Summarize Source of Wealth: g Buenas Owner O Salary/Earnings 2 Investment O Inheritance/Gifts O Other: Futile Describe Source of Wealth /Detail the tistoey of wealth for each of the scums: (e.g. For trusts, how did settler acntrulate wealth? For inheritance, how Si fan* accumulate wealth?For business owners, how long in business, how many employers, level of prontaNlity? Indicate type of business, countries of major activities, important business partners.) Jeffrey Edema' Epstein (born January 20, 1953) is an Amerkan (Mender and **game sex offender n the Wiled States. He worked at Bear Steams early n his career and then famed his own fkm, 1. Epstein & Co. In 2008, Epstein was Convicted of soboting an underage gin for prostitution, fa which he served 13 months in prison. He Ivies in the US Virgin Islands. EpsteM taught catulus and physics at the Dalton School in Manhattan from 1973 to 1975. Arnong his students was a son of Alan C. Greenberg, chairman of Bear Stearns. In 1976, Fasten started work as an options trader at Bear Stearns where he worked in the special products division, advising Ngh-net-worth clients on tax strategies. Proving successful in cis financial career, in 1980 Epsten became a partner at Bear Stearns. In 1982, Epstein founded his own financial management firm, J. Epsten & Co., managing the assets d dents with more than $1 billion in net worth. In 1987, Leslie Wexner, founder and chairman d Ohio-based The Limited chain of women's clothing stores, became a wed-knovm client. Werner acquired Abercrombie & Etch the felbning year. In 1992 he converts a private school on the Upper East sde Into an enormous residence. Epstein later bought that property, in the wealthiest part of Manhattan. In 1996, Epstein changed the named his firm to the sandal Trust Company and, for tax advantages, based it on the sand oft Thomas In the US Virgin Islands. In 2003, Epstein CO to acquire New York magazine. Other ladders were advertising executive Denny Deutsch, investor Nelson Pet, media mogul and publisher Mortimer Zuckerman, who had the New York Daly News, and film producer Harvey Weinstein. They were ultimately outtid by Bruce Wasserstein, a longtime Wall Street Investor, who pad $55 million. In 2004, Epstein and Zu:kerman committed up to $25 mson to finals Radar a celebrity and pop cuture magazine fended by Meer Roshan. Epsten and Zuckerman were equal partners in the vette. Roshan, as its edict-in-chief, retained a grail ormershp stake. Po:sentry, Mr. Epstein founded Southern Trust Company Inc, a private consulting company that invests the assets of their clients and gets their revenue from the return of these Investments. Southern Trust invests in different pa-tit:dos catered to their dents and makes their revenue based on the returns and the fees associated with managing their client's assets. SDNY_GM_00037478 CONFIDENTIAL- PURSUANT TO FED. R. Ce I ONFIDENTIAL h tps://dbforcepb.my.salesforce.com/servlet/servletintegration?lid=01N30000000D9Di&e... 7/11/2019 DB-SDNY-0000302 EFTA_00148090 EFTA01282187  KYC Print Page 4 of 10 Estimated Annual Imome($): 10,00%000.00 Estimated amount d investatfe assets(S): S50 MM - 100 Mel Estimated Net Wath(S): $500 MM + Amount of assets plains to invest with PWM(S): Other Known Financial Institubcos: Institution: Country: Est. Assets Under Mgt: Institution: Country: Est. Assets Under Mgt: Institution: Country: Est. Assets Under Mgt: Please in&ate the family sAuaUdi of the incfMdual (marital stabs, otter family members, etc.): SDNY_GM_00037479 CONFIDENTIAL - PURSUANT TO FED. R. Ce I ONFIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... 7/11/2019 DB-SONY-0000303 EFTA_00148091 EFTA01282188  KYC l'rint Page 5 of 10 One sheet must be established for EACH INDIVIDUAL PARTY In Section 2. Account Ownership Summa 3A. Individual Details (for all pubes) Individual's Name: Wallace, Daohre - Date of Birth: 6/19(1967 Country of Residence: USW Country of Citizenship: USVI Has client resided outside d Ns/her country of nationally for Oyes 5 No Address of primary residence: 5 years or more? ProfessionfOxupation: Finance Tax ID / SSN: Current Employe: Southern Trust Company Inc Position/Title/Rank: controller Address of employer: 6100 Red Hock Quarter St Thomas United States 03802 Does the person work as senior executive of a DB-recognized regulated entity in the financial ndustry? Of an entity aged on a DB-recognised exchange? (Not applicable for operating entities 0YaIONo I5 the indhidual a Politically Exposed Person (PEP)7(d ❑Ores @to der*/ To the best of yow knowledge. Is the Indhidual related to an employee of the DB group?(eNswair or O Family O Friendship 2 Nene Friendship, tome) To the best of your knowledge, is the individual party to a non-baniong tattoo() wth Deutsche Bank (e.g., external legal counsel, client referral sowce, Replier of goods or unices)?(ff Oyes 171No Yesdesatie) Indicate where and when the client meeting(5) took place: If appicable, indicate which bank officers Nye met the person: Client Private Cent Raced Bank Officer Names) Bank office: Other Othe Location (specify): Date: [amble: Business: O O O O O O O O O O wealth Details for this individual are not Med In, because they are the same as for the following person: 3B. Wealth Details (Only for parties requiring sane of wealth description as Indicated in SectIon 2) Nature of the Individual's Business: Winery Country of source of wealdVsource of Funds? or/ran' industry of source of Wean/Source of Funds? Summarize Source of Wealth: O Maness Owner O Salary/Earrings O investment O inmotance/Girts O Other: Further Describe Source of wealth meta the hstory of wealth for each of the sources: (e.g. For bras, how did settle accenulate wealth? For Inheritance, how did fan* accumulate wealth?For business owners, how long In engine's, how many employees, level of prcntability? Indicate type of business, countries of major activities, important business panes.) Estimated Annual Ireame($): Estimated amount of (v table assets(5): Estimated Net Werh(5): Amount of assets panned to invest with PW74(5): Other Known Financial Institutions: insbtLieon: Country: Est. MSS Under Mgt: inotution: Country: Est. ASSerS Under Mgt: IndefurdOn: Country: Est. ASSere Under Mgt: Please inch:ate the family situate, of the iranidual (marital stabs, otter family members, etc.): SDNY_GM_000374S0 CONFIDENTIAL - PURSUANT TO FED. R. Ce I ONFIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servletintegration?lid=01N30000000D9Di&e... 7/11/2019 DB-SONY-0000304 EFTA 00148092 EFTA01282189  KYC Print Page 6 of 10 One sheet must be established for EACH INDIVIDUAL PARTY In Section 2. Account Ownership Summa 3A. Individual Detaes (for all parties) Indlviduars Name: Groff, Date of Birth: 10//41966 Country of Residence: USA Country of Citizenship: USA Has client resided outside of Address of primary residence: Ns/her wintry of nationally for Dyes into 5 years or more? Profession/Occupation: Attorney Tax ID / SSN: Current Employer: Darren K Indyke PLLC PosIticrVTIUWRank: Attorney Address of empOyer: 575 Lexington Avenue 4th FL new work NY United States 10022 Does the person work as senior executive of a DB-recognized regulated entity In the financial ndustry? or an entity aged on a DB-recognised exchange? (Not boob:sob* for operating entities • Ws 0 No Is the indlodual a Politically Exposed Person (FEP)?(if Yes, otexigu) ates 2 No To the best of yow knowledge. Is the IndNidual related to an employee of the DB group?0fPam* Or O Family O Friendship 2 None Friendship, desothe) To the best of your knowle6ge, Is the individual party to a non-banking relationship wth Deutsche Bank (e.g., external legal counsel, client referral soiree, suppler of goads or sinAces)?07 ales 171No Yesdesentre) Indicate where and when the client meeting(%) book If appleable, Indicate which bank officers have met the person: Client Private Crent Place of Bank Officer Names) Bank Office: Other Location (specify): Date: Donnie: Business: O O O O O O O O O O Wealth Details for this IndiVdual are not filed In, because they are the same as for the following person: 3B. Wealth Details (Only for parties requiring scarce of wealth description as indicated in Section 2) Nature of the Individual's Business: Primary Country of source of wealth/source of Funds? Primary industry of solace of Weatifigourced Funds? Summartze Source of Wealth: O Baseless Owner O Salary/Earnings O Investment O Inheritance/Gifts O Other: Father Describe Source of Wealth /Derail the Nstory of wealth for each of the sources: (e.g. For trusts, how did settler ace...notate wealth? For Inheritance, how Ofd family annulate wealth?For business owners, how long In business, how many employees, level of praitability? Indicate type of business, countries of major activities, apatant business partners.) Estimated Annual Inoame($): Estimated amount of investable asses(5): Estimated Net Worth(S): Amount of assets plumed to invest with PW74(S): Other Known Financial Institutions: InsritUdon: Country: Est. Assets Under Mgt: InsritUdon: Country: Est. Assets Under Mgt: Insbtrldon: Country: Est. Assets Under Mgt: Please Indicate the family situatron of the incfrAdual (marital stabs, other family members, etc.): SDNY_GM_00037451 CONFIDENTIAL - PURSUANT TO FED. R. Ce I ONFIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=0IN30000000D9Di&e... 7/11/2019 DB-SONY-0000305 EFTA_00148093 EFTA01282190  KYC l'rint Page 7 of 10 One sheet must be established for EACH LEGAL ENTITY In Section 2. Account Summit 3C. Legal Entity Details (Foe al Legal Entities) Legal Entity Name: The 2017 Caterplar Trust - 00000S7S9E0 Type of Entity: • FoLodatron/Associatlon HI Trust O Company O Estate O Noose of Eray: g Private Investment O Partnershp Flilianthr0PIC/Cteritatte O Commercial Purpose el Entity Cther 'Pape of Entity Other (specify): (specVy): Country a Virgo Islares, U.S. Date of Ina:tamale)/ 43/2017 occeporationffegistratron: registration: Determination Required No Volcker Status: Vokker Flag: 6100 Red Nook Quarter 83, St Thomas 00802 UNted States U.S. TIN/EIN: Address (ay, street, post cede): PtcMde a description a the entity's organizational structure, is ownership structire and Its Top Management. Fa busts/foureations, inclikle information about reyccaNlity,settlor and tenelidaries,etc: this is a grantor retained annuty trust that holds membership interest in IGO Company U.C. This trust will terminate two years from the date of initial funding and annual annuity distributions will be paid to the grantor only. Upon termination, the membershb interest wall then transfer to the 2013 Butterfly Trust. Grantor: Sftri Jef ...: Trustee: and Daphne Wallace Beneficiaries: Jeffrey Epsten and The 2013 Butterfly Trust (Loco termination of trust) Please indkate how ownership of the legal entity is reflected: trust agreement O Spada attention: Bearer Shares - Indicate where shares we custodied: Describe the chain flan the direct owner of the entity to the ultimate benefiCial owner (loot Me same pawns) Grantor: Jeffrey Epstein Trustee: and Daphne Wallace Beneficiaries: Jeffrey Epstein and The 2013 Butterfly Trust (upco termination of Oust) To the test of your knovfledge, is the entity party to a non-banking reationship veith Deutsche Bank I (e.g. external legal mune, client retell source, supplier of goods or services)?: Yes O NO Describe Nature of Entity's Primary Business and Investment Activities Nature of the tipsiness: This Is a grantor retained annuity trust that holds rnembersNp interest in IGO Company U.C. Countries where busines k transacted: usa Number of employees: 0 30. Wealth Profile (Only for parties requiring souse of wealth description as indicated in Sectbn 2) Primary Country of source of wealth/source e Funds? Primary industry of saute of Wealth/Source of Funds? Picnide Evidence of Corporate Assets (e.g. balance sheet a eq tralent summay or assesillabilltres): The source of wealth for this trust derhes from Jeffrey Epstein. Please revert to his source of wealth for more detait.. Estimated gross receipts p.a.($): 1,000,000.00 Estimated net plait p.a. (5): 1,000,000.00 Estimated investable assets ($): SI MM - 2 MM Potential AMOUrbt to be invested with MUM (5): 1,000,000.00 Other Know', Financial Institutions: laser/Jon: Country: Est. Assets Under Mgt: InstturJon: Country: Est. Assets Under Mgt: InstturJon: Country: Bt. Assets Under Mgt: SDNY_GM_00037482 CONFIDENTIAL - PURSUANT TO FED. R. IA I ONFIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servletintegration?lid=01N30000000D9Di&e... 7/11/2019 DB-SONY-000030S EFTA_00148094 EFTA01282191  KYC Print Page 8 of 10 DB PWM GLOBAL KYC/NCA: US/LatAm/1M1 PART B Ftelatienshp Name SOUTHERN FINANCIAL RELATIONSHIP Risk Rating Laments: Boling Center 0 NY O NY/Offshore O offshore V skr.bderate OHO RNA ]Teensuri thong (Compliance Signature) O DB Employee Doe Managed PIC O DB Is Trustee/Co-Trustee O Bearer Shares 4. Attachments A. Type et Photo ID Frowided @ Drivers License Passport O National/State ID O Other B. Checklist of names (indiAduals and/or entitles) that were submitted fa database seethes Is attached Oyes O No C. Please inlcate the results of the database searches pertained FtDC searches complete ®Yes O No negative results found O Yes 12 No PCR checks complete ®Yes O No negative results found O Yes 0No OFAC checks complete 10 Yes O No negative names found O Yes OM BIS searches complete (Lees/Nees, Factka, Reuters, Dow Jones, DAB) ®Yes ElNo negative names found O yes @No Denial Orders checks complete ®Yes O No negative !1st found O yes El No Mailindare-Hubeell searched (LawyersfLaw Firms only) Oyes @No negative results Found Oyes O No D. Please summarize any negate.* results from the database searches indicated above: E. To the best of your kneAtedge, has the diet ever been convicted of a criminal offense? ®Yes ONo To the best of your knairtedge, has the customer ever been invoNed in any past ItigaUcti against E Deutsche Bank AG or any of its subtleties or is the customer [Neatening litigation against Deutsche 5 No Bank AG or any of its Sot:hares? (If Yes prey.* deals below onflcontact Quaky Mgt aatiroWnW or Yes the ReSeditay Control &OOP andnotify Compliance immeStely) Does the dent or related party have any Maids a other association f interacUens wthin COUrarleS or • 0 No G. Yes mama sanctioned by the Dmce of Fordgn Assets Control (OFAC)? Does the cleat or related party have any Enatial or other association/ interactions within high risk N. O Yes @No countries? I. Corporate Documettarien Attached (Legal Entities 000 ®Yes O No O Notary/caw J. Undisclosed Prinlpal Form Complete (Intermediaries Only) • Yes • No 2 Not eopecaNe K. If Leis/Neils Search Resift, Corporate momentsor Other Supporting Documetada) is net in English, please provide an Enoch summary of the Toffee/octets of the non-Enosh Documentation: L. Special RI Factors Does the account have Nears to Special Risk Countries? Ores 0 No Is the a:cowit StrLICRIM initially complex? Oyes RIND is there any indicate, the client se up a ron operating company expressly for O yes 2 No the purpose of transferring shares to [NM pates? Is thee any indicatbn this could be a prohibited business relationship? Dyes 12 No Are the bearer shares deviled subject to acceptable controls? Dyes 121reo SDNY_GM_00037453 CONFIDENTIAL - PURSUANT TO FED. R. IA I ONFIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... 7/11/2019 DB-SONY-0000307 EFTA_00148095 EFTA01282192  KY(' Print Page 9 of 10 M. Case Comments Created By Date Comments Your,Ur CI i. , ', 4 3/18/118 10:52 AM The client Trust is regstened in US VI, not USA. TNs Kit senes as a Ngh risk review for the new client The 2017 Caterpilar Trust (referred as accountholder') - Below are the reasons why we are comfortable with approving this KYC: • Intl:gyration and supporting documents recryAred by our NIL Poky were provided and reviewed; and as a resit we "rave an understanding of the struchre of the accountholders, thee propose, the purpose of the accounts and expected 3ansaction actNity. • Thee are a few risk factors associated with the accountholder- Matthew-3 Purcell 2/13/118 11:13 AM SOW: The UBO (Jeffrey Epstein) Is the 'molder of Southern Trust Company Inc. Witch manages clients assets. SOW verification was obtained. Negative Meda & PEP: There is some negative media against Mr Epstein and he is also maintains a dose Satonship wth EA Clinton and Prince Mdrew. Please see rid( calculator for more information. Appropriate approval vas obtained. • Our refew did not identify any red flags and thus there was no need to escalate the case further. • We performed due dibgence searches on all parties and did not find the names searched to be on any sanctions lists Please Note: The 2013 Butterfly trust is listed as a beneficiary only when the 2017 Caterpilar Trust terminates. Since Cynthia Rodriguez 2/8/118 10:59 AM this benefbary does not receive the annual annuity payments, ewes not added as a party. However, there attached the trust agreement and list of beneficiaries for this trust as support ONSHORE APPROVALS Client Facing Professional (CFP): stewart °Weld ;Sgnatue) 2/8/2018 stewart (Wed Office Deector/Business Head: Mdrew F Gallivan (Signature) 2/8/2018 Mdrew F Gallivan Regional Office Director: (Signature) AML Business Risk: (Signature) AML Compliance: (Sgnature) Matthew-) Purcell Matthew-) Purcell 2/13/2018 Yoonsun Chung Yoonsun Cliung 2/13/2018 tATAm / INTERNATIONAL APPROVALS Client Facing Professional (CFP): (Signature) Account Manager: (Striatum) Global Market Team Head (GMTH)/Sub- (Signature) Market Team Head (SMTH): AML Business Risk: (Sgriature) AML Compliance: (Signaturel PRIVATE WEALTHMANAGEMENTPOLICY STATEMENT: Deutsche Bank Private Wealth Management (PWM) worldwide is committed to professionally serve the interests ofits clients. To do so, Client Facing Professionals1(1) (CFP's) should establish and maintain business relationships only with persons who swish, our high standards ofsuitability, background and character. Due diligence obtained on the client must be appropriately documented by the CFP. It is the responsibility ofCFP's to demonstrate that they know their client both at the inception ofa relationship and on an ongoing basis. SDNY_GM_00037484 CONFIDENTIAL- PURSUANT TO FED. R. IA I ONFIDENTIAL https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... 7/11/2019 DB-SONY-0000308 EFTA_00148096 EFTA01282193  KYC Print Page 10 of 10 DECLARATION FOR ALL SIGNERS OF THIS FORM: To the best ofmy knowledge and belief the above information is correct and up to date. I confirm that I have no suspicions relating to the money laundering or unethical activities on the part ofthe client(s) and that I havefollowed all theprocedures relating to account opening as described in the PWMAmericas Procedures and the PWM Global KYC Policy (1) Client Facing Professionals (CFP's) include: Relationship Managers, Wealth Advisors, Product Officers. Brokers. Client Managers, etc.