📄 Extracted Text (4,265 words)
KYC Print Page I of 14
DB PWM GLOBAL KYC/NCA: PART A
KYC Case : 01651789 Status : 6. Approved
One sheet must be established per relationship - list all accounts Included In the relationship
1. Relationship Details
Relationship Name: EPSTEIN, JEFFREY RELATICtISHIP:000004.33290 Booking Center: I New York
Relationship Manager: Stewart Oldfidd
• New PWM Relationship I ❑ Existing PWM Relationship
Relationship to PWM:
If existing, please indicate since when the relationship exists, provide reason for new profile and attach old profile: Update of
KYC M01133113. Beneficianes have changed
RI Client Referral I❑
RM Prospect to Intermediary/FM t ❑ Other Source (CO3, etc.)
How Was the C hent(s)
Introduced, Flow long has the
RN personally known the Please provide details (e.g. name of referral source, ow many ears RM personally h s known dent, etc.): Jeffrey Epstein
client' (President of Gratitude America) Is a current client of the bank and reached out to Stewart Oldfield to update the beneficiaries
to his Butterfly Trust.
Does Deutsche Bank pay a ❑ Yes EZ No
retrocession or similar
compensation to a third party
for the introduction of des (ff Yes, descnte):
relabonship>
List all existing and new accounts involved in this relationship
Legal Entity Account Name / Number Opening Date (intended/actual)
Account(s)
1 Et Butterfly Trust — Checking 10/9/2013
2 irri Butterfly Trust -- Money Market 10/9/2013
Who Is the primary contact
Person for the RM? (Note:
Preferred method of contact
This person needs to have Harry Beier
signatory rights and/or (ndicate phone no., fax no.,
e-mail address, etc.):
infermatko right for the
accounts.):
SDNY_GM_00039985
hups://dbforcepb.my.salesforcaINBIDErNIJIAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED R CRIM. I.6(e) DB-SDNY-0002809
EF1'A_00150594
EFTA01284072
KYC Print Page 2 of 14
One sheet must be established for each account to be opened
2. Account Ownership Sunman,
Account Name: Butterfly Trust — Checking Acct. Number Atavaibbiel
Account Manager: Paul Marls
What is the purpose d the account (e.g. portfolio maned ment, advisory account, custody services, longterm investment, paymenbexpense account)", TM 6
a checking account to hold funds for the bust
Indicate from where the assets are expected to arrive>
O DB Group: Same Booking Center (inScate account number):
O DB Group: Other Booking Center (Indicate DB location and account deeds):
RI Other Institution (Incicate name & location): WMorgan. New York, NY
O Physical Deposts (specify cash, securties, cheques, ...):
What Is the expected size and frequency of regular Inflows and outflows for the account (ndicate estimated number and volume per month), . Roughly 5- JO
Inflows and outflows per month ranging from $1,000 to $20,000
What is the expected volume of assets and cwrency for the account approx. 90 days after I Currency I lisp
°Peeling> I
What is the expected volume of assets and currency for the account approx. one year after 15,000,000.00 iCurrer:y I u$0
opening>
Does/VAII the client have Assets Under Management (AiiM) within CB under Eur. 3M' 0 Yes Olio
Please list aN parties related to the account.
For each party:
• Check if a source of wealth description is required for the party.
• check the appropriate box to describe the relationship of the party to this account (> I can be selected).
• If none of the check bones apply, describe the party, relation to the account in the -Other column.
• Ahneys describe the relationship between the patties in the last olumn.
• Please dril down to the ulbmate/undertylng Beneficial Owner(s)
_egal5esaipbcri AccoundalC Seth'''. of JIlknate BegnatorNiyatedFinanclal Significant Legal Grantor/Senior Freunclingtiber
Enbtrof Source Holder OmerTrust / Beneflciabr Full iCIA IntermediaryShareholderetepresentabve 3orsor (please
Fl Wealth Founder orJrwrier ?OA (FIM) (>=25%) describe
required Found.Thon Non-PIC other roles
entity and/or
Parties (indicate ndicate
related ownership -elationship
tothls Y:i) between
account ladles)
1 O 2 Jeffr
ey I--,
Epstein n
Do
❑ O O L., LJ O O • Grantor;
2 0 0 Ha" CI
Baer 0 • W
•1 M 0 0 0 0 Tivstee:;
II
Erica
3 O O Kellerhals • O O O 2 O O O O • Trustee::
Butterfly E Do
4 Iii El
Trust ❑ • O O O O O O
SONY_GM_00039986
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CONFIDENTIAL - PURSUANT TO FED R CRIM.I. 6(e) DB-SDNY-0002810
EFFA_00150595
EFTA01284073
KYC Print Page 3 of 14
2. Account Ownership Summary
Account Name: Butterfly Trust -- Money Market Acct. Number Of evadable).
Account Manager: Paul Morris
What Is the purpose et the account (e.g. portfolio management, advisory account, custody services, long-term investment, payment/expense account)' Money
Market account. To hold cash for the trust to earn interest
Indicate from where the assets are expected to arrive?
O DB Group: Same Booking Center (Indicate account number):
O DB Group: Other Booking Center (Indicate DB locator, and account defiles):
741 Other Institution (Indicate name & locator): 1PMagan. New York, NY
O Physical Deposes (specify cash, secureies, cheques, ...):
What Is the expected it and frequency of regular Inflows and outflows for the account (prithcat estimated number and volume per month)? Roughly 1-2
Inflows and outflows per month ranging from $1,000 to $10,000
What Is the expected volume of assets and currency for the account approx. 90 days after I I Currency I USD
°Peeling'
What is the expected volume of assets and currency for the account approx. one year after 1,000,00°00 I Currency I USD
opening'
Does/nill the client have Assets Under Management (AiiM) within C43 under Eur. 3M, I Yes 5 No
Please list all parties related to the account.
For each party:
• Check If a source of wealth description Is required for the arty.
• Check the appropriate box to describe the relationship of the party to this account (> 1can be selected).
• f non of the check bares apply, describe the partys relation to the account In the 'Other' column.
• Ahsays describe the relationship between the parties in the last olumn.
• Please drill down to the ultimate/underlying Beneficial Owner(s)
_eganescnpbcn AccounWIC Settlor of JIbmate Sgnatorytinvtedkinancial Significant -egal Grantcr/SettbrfoundingOther
Entity of Source Holder OnnerTrust / Seneficiafx Full POA ntermedery Sharehdderetepresentabve Donor (please
of Wealth Pounder of3vmer ?OA IM) (>=25%) describe
required Foundation Non-PIC other roles
entity and/or
Parties (Skate ndicate
related ownership relations*,
to this ib) between
account males)
Jeffrey • ei
I O g r—i O O O O O O O Granter;
Epstein "
2 2) 5 eljtterrtY 5
Trust O O O O OO O O O
any a • O
3 O O I E1 O M O II O Trustee:;
BMeller
Erika
4 • O O O • Ed O O • O O Trustee:;
Kellerhals im
SDNY_GM_00039987
hups://dbforcepb.my.salesforeCLINErilEaltiAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. I. 6(e) DB-SDNY-0002811
EFTA_00150596
EFTA01284074
KYC Print Page 4 of 14
One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summary
3A. Individual Details (for all parties)
Indhnduars Name: Jeffrey Epstein - 00000483289 Date of Birth: 1/20/1953
County of Residence: USVI Country of Cedenship: USA
Has dent resided outside of
Utte Saint lames Saint Thomas 00802 his/her country of nabonality Oyes ®No
Address of primary residence:
for 5 years or more'
Profession/Occupation: Self Empolyed Tax ID / S511: 090-44-3348
Current Employer: Southern Financial LLC Position/Me/Rank: President
Address of employer: 6100 Red Hook Quarter 93 St. Thaws 00802
Does the person work as senior executive of a DO-recognized regulated entity In the financial GI
ndustry' or an entity listed on a DO-recognised exchange? (Not applicable for operating entities i--i Yes
ICS r2-1 No
Is the individial a Politically Exposed Person (PEP)>(d Yes, descnbe) 0 YeS 0 No
To the best of your knovAedge, is the individual related to an employee of the DB group>(f 0 Family 0 Friendship 5 None
firnO, or FrencWup, desathe)
To the best of your knowledge, is the individual party to a nal-banking relationship with
Deutsche Bank (e.g., external legal counsel, client referral source, suppler of goods or O Yes J No
serykes)'(rf YeArfesage)
If applicable, indicate which bank officers have met the Indicate where and Mien the dent meebng(s) took place:
Perkin:
Ghent Private Client Place of
Bank Officer Names) Bank Office: Other Location (specify): Date:
Domicile: Business:
Paul Morris O • 0 9/13/2013
O O O
• • 0
0Wealth Details for this individual are not filled in, because they are the same as for the fdlowing person:
38. Wealth Details (Only for parties requiring source of wealth description as indicated in Section 2)
Nature of the Individual's Business: Private investments
Primary Country of source of wealth/source of Funds'
Primary indusby of source of Wealth/Source of Funds'
r._.,
Summartze Source of Wealth: Ki Business Owner 0 Salary/Earnings Rilmestment 0 Inheritance/Gifts 00ther:
Further Describe Source of liVealth /Detail the history of wealth or each of the soaps: (e.g. For trusts, how did settler accumulate weami' For Inheritance,
how did family accumulate wealth?For business owners, how long in business, how many employees, level of profitatilty? Indicate type of business, countries
of major activities, important business partners.) Epstein began his financial career in 1976 as an options trader at Bear Steams and became a partneri n
1980. In 1982, Epstein founded his own finandal management firm, J. Epstein & Co., managing the assets d clients with more than a billion in net worth. In
19%, Epstein changed the name of his firm to The Financial Trust Company and based It on the Island of St. Thomas In the US Virgin Islands. MI of his clients
were anonymous except for the very wealthy businessman Leslie Wexner. /4s wealth has come from his days at Bear Steams and his financial management
firms
Estimated Annual Income(S): 10,000,000.00 Estimated amount of investable assers(S): $50 WI • 100 MM
Estimated Net Wortli(S): $100 MM - 500 MM Amount of assets planned to Invest with PWM(S): 5,000,000.00
Other Known Financial Institutions:
Insbbibon: JPM Country: USA Est Assets Under Mgt: 120,000,000.00
SONY_GM_00039988
https://dbforcepb.my.salesforCLINErilDairdiAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. I. 6(e) DB-SDNY-0002812
EFTA_00I 50597
EFTA01284075
KYC Print Page 5 of 14
Institution: Deutsche Bank Country: USA Est Assets Under Mot 70,000,000 00
InstibAion: Country: Est Assets Under INt
Please indicate the family skuabon of the individual (marital status, other family members, etc.):
SONY_GM_00039989
littps://dbforcepb.my.salesforcCaNtEll0EgSdiA110000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R 6(e) DB-SDNY-0002813
EF1'A_00150598
EFTA01284076
KYC Print Page 6 of 14
One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summary
3A. Individual Details (for all parties)
Indus:lust's Name: Harry Baler Date of Beth:
County of Residence: USA Country of Citizenship: USA
Has dent resided outside of
his/her country of nationality O Yes ®No
Address of primary residence:
5 years or more
Profession/Occupation: Accountant Tax ID / SSN:
Current Employer: HUNK Associates, Inc Position/Tele/Rank:
Address of employer:
Does the person v.ork as senior executive of a DB-recognized regulated entity In the financial m
ndustry' or an enbty listed on a CB-recognised exchange' (Not applicable for operating entitles Yes ®No
Is the individual a Politically Exposed Person (PEP)W Yes, *untie) ails ga No
To the best of your knowledge, is the individual related to an employee of the D8 group'(/ . Family °Friendship 5 None
Family or Friend:lag descrthe)
To the best of your knowledge, is the individual party to a non-banking relationship with
Deutsche Bank (e.g., external legal counsel, client referral source, suppler of goods or O Yes ENO
serykes)'(tY Yes,rfescnte)
If applicable, indicate which bank officers have met the Indicate where and Wien the client meetirxXs) took place:
PerSOn:
Client Private Client Plated
Bank Officer Names) Bank Office: Other Location (specify): Date:
Domicile: "rosiness:
• • O
O O O
ri O O
• weatth Details for this individual are not filled in, because they are the same as for the following person:
38. WeaRh Details (Only for parties requiring source of wealth description as indkated in Section 2)
Nature of the Individual's Business:
Primary Country of source of wealth/source of Funds'
Primary industry of source of WealtIVSource cf Funds'
Summarize Source of Wee*: 0 Business Owner O Salary/Eamings O Investment O Inheritance/Gifts 00ther:
Further Describe Source of Weahh /Detail the history of wealth or each of the scores: (e.g. For trusts, how did setbor accumulate wealth' For inheritance,
how did family accumulate wealth?For business owners, how long in baseless, how many employees, level of profltatility? Indicate type of business, countries
of major activities, important business partners.)
Estimated Annual Income(S): Estimated amount of Investable assets(5):
Estimated Net Worth(S): Amount of assets planned to Myst with PWM($):
Other Known Financial Institutions:
InstibAion: Country: Est Assets Under Mgt:
Institution: Country: Est ASsetS Under Mgt:
InstMition: Counby. Est Assets Under Mgt.
SDNY_GM_00039990
https://dbforcepb.my.salesforcaaNtalacriNaliAL000000D9Ditice... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. 1.6(e) DB-SDNY-0002814
EFTA_00150599
EFTA01284077
KYC Print Page 7 of 14
1 I I
Please nelicate the family stuabon of the individual (marital status, other family members, et):
SDNY_GM_00039991
Imps://dbforcepb.my.salesforcaINEJIDErNidiAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED R CRIM.I. 6(e) DB-SDNY-0002815
EFTA_00150600
EFTA01284078
KYC Print Page 8 of 14
One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Somme
3A. Individual Details (for an parties)
Individual's Name: Erika Kellethals Date of Birth:
County of Residence: USA Country of Citizenship: USA
Has dent resided out& of
his/her country of nationality IIII Yes Ea No
Address of primary residence:
kw 5 yews or more'
ProfessioniOccupation: Attorney Tax ID / 55N:
Current Employer: Kenerhals Ferguson Kroblin PLLC POSItiangPM/Ranic
Address d employer:
Does the person work as senior executive of a DB-recognized regulated entity In the financial n
ndustry' or an entity listed on a Cewecognised exchange' (Pict applicable for operating entitles Yes ONO
Is the individual a Politically Exposed Person (PEP)W Yes, describe) Oyes Et No
To the best of your knowledge, is the individual related to an employee of the DB groupyrie O Family O Friendship EA None
Family or Friendship, (Wage)
To the best of your knowledge, is the individual party to a non-banking relationship with
Deutsche Bank (e.g., external legal counsel, client referral source, suppler of goods or O Yes El No
services)' i Yes,ekuthe I
If applicable, indicate which bank officers have met the Indicate where and when the c rent meeting(s) took place:
person:
Olent Private Client Place of
Bank Officer Name(s) Bank Offke: Other Location (speedy). Date:
Danielle: Business:
• • O
O O O
El O O
°Wealth De at fa this Individual are not filled in, because they are the same as for the following person:
98. Wealth Details (Only for parties requiring source of wealth description as Indicated in Section 2)
Nature of the Individual's Business:
Primary Country of wane of wealth/source of Funds'
Primary industry ci source of WeatIVSoince of Funds'
Surnmarke Source ci wealth: O Business Owner O SalarwEamings O investment I:Inheritance/Gifts 00ther:
Further Describe Source of Wealth /Detail the bitty of wealth or each of the sources: (e.g. For trusts, how did setdor accumulate wealth' For mhentance,
how did (amity accumulate wealth?For business owners, how long in business, how many employees, level of profitability? Indicate type of business, countries
of major actwtbes, important business partners.)
Estimated Annual Incorne(S): Estimated amount of Investable assets(5):
Esbmated Net Worth(d): Amount of assets planned to nest with PWN($):
Other Known Financial Insteunans:
Institution: Counby: Est. Assets Under Mgt:
Institution: Counby: Est Assets Under Mgt:
Instfbation: Counby. Est Assets Under Mgt.
SONY_GM_00039992
Imps://dbforcepb.my.salesforcGCaNtEllOalTdiA10000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED R CRIM.I. 6(e) DB-SDNY-0002816
EFTA_00150601
EFTA01284079
KYC Print Page 9 of 14
I I I
Please indicate the family stuabon of the individual (marital status, other family members, etc.):
One sheet must be established for EACH LEGAL ENTITY in Section 2. Account Sum.
3C. Legal Entity Details (For al Legal Entities)
Legal Entity Name: Barfly Trust - 00000486426
Trust O Company O Estate
Type Purpose of Enbt`l, Ph danthreph/Chatitabie n
O PartnerShiP
Commercial
Purpose of Ent*
Type d Enbty Other (specify): Other (specify):
C
Country of USA Date of
12r 27/2006
incorporation /
(neap:ration:mg eaten
registration:
Determination Regaled No
Volker Status: Wicker Flag:
Address (city, street, post 6100 Red Hook Quarter B3 SL Thomas 00802 United States US. TINIEIN: 26-6639711
code):
Provide a description of the en rtys organizational stnxture, Its ownership sbudure and Its Top Management. For trusts/foundabons, Include information about
revocability,settlor and bench° nes,etc.:
This is an irrevocable trust set p by Jeffrey Epstein as the grantor. The the beneficiaries for the trust are being updated by the current trustees. The trustees
n rika Kellerhah. The benefiriarles are:
lin
Darren Indyke
2 Kean Court
UvIngston, N) 07039
Karyna Shullak
301 East 66th Street
New York, NY 10065
lUchard Kahn
130 East 75th Street
New visit, NY 10021
SONY_GM_00039993
Imps://dbforcepb.my.salesforcCLINEJIDErhilidiAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R 6(e) DB-SDNY-0002817
EFTA 00150602
EFTA01284080
KYC Print Page 10 of 14
Attached are the original bust agreement and the addition/deletion of beneficiary Instrument to support this change. According to the original trust agreement,
the trustees have the right during the lifetime of the Grantor to delete or add beneficiaries under Mkt< 3 of the agreement.
Please Skate how ownership d the legal entity is reflected: trust agreement
O Special attention: Bearer Shares • Indicate where shares are custodied:
Describe the chain from the direct owner of the entity to the ultimate beneficial owner Ofnct the same persons): This is an irrevocable trust set up by Jeffrey
Epstein as the grantor. The the beneficiaries for the trust are being updated by the current trustees. The bustees are Harry Belkr and Erika Kellerhals.
To the best of your knowledge, is the entity party to a non-banking relationship with Deutsche
Bank (e.g. external legal counsel, client referral source, supplier of goods or services)': Yes el No
Describe Nature of Entity's Primary Business and Investment Activities
Nature of the business: Trust account
Countries where business is transacted: USA. USVI
Number of employees: N/A
3D. Wealth Profile (Only for arbes requitmg source of wealth description as indicated in Section 2)
Primary Country of source of wealth/source of Funds'
Primary industry of source of Wealth/Source d Funds'
Provide Evidence of Corporate Assets (e.g. balance sheet a equivalent summary of assets/IlaNties):
Trust account with Jeffrey Epstein as Grantor. Initial $100 given to the account to fund. The funds for this trust account come from investments made by Jeffrey
Epstein. His wealth profit is filled out The trust is for the benefit of the 6 named IndNiduak
Estimated gross receipts $): 4,500,000.00
Estimated net profit a (s): 4,500,000.00
Estimated Investable assets ($): $5 MM - ICI MM
Potential Amount to be invested with PWM ($): 4,500,000.00
Other Known Financial Institutions:
Institution: JPMorgan Country: USA Est Assets Under Mgt 4,500,000.00
Institution: Country: Est Assets Under Mgt
Instibition: Country: Est. Assets Under Mgt
SDNY_GM_00039994
https://dbforcepb.my.salesforeCLINErilDairdiAL000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. I. 6(e) DB-SDNY-0002818
EFTA_00150603
EFTA01284081
KYC Print Page 11 of 14
DB PWM GLOBAL KYC/NCA: US/LatAm/InCI PART B
Relationship Name EPSTEIN, JEFFREY RELATIONSHIP
Risk Rating Comments:
Booking Center O Yoonsun Chung
E High Risk
El NY
NY/ Offshore
E Offshore O M“ knte
Risk ]
(Compliance Signature)
• DB Employee M 08 Managed PIC 7 DB is Trustee/Co-Trustee • Bearer Shares
4. Attachments
A. Type of Photo ID Provided @Drivers License 0 Passpat ONalknal/State ID Daher
Checklist of names (Individuals and/or entitles) that were submitted for database searches Is
B. are Otio
attached
C Please indicate the results of the database searches performed
RDC searches complete it Yes 0 No negative results foal @Yet ONO
PCR checks complete 0 yes O No negative results found ®Yes Otto
OFAC checks complete Ora O No negative results found O Yes 0 NO
BIS searches complete (Lest/Nods, Factiva, Reuters, Dow Jones, MB) Oyes ONO negative results found ®Yes O No
Denial Orders checks complete ayes O No negative results found Ora n No
Martindale-Hubbell searched (lawyers/Law RIMS only) 0 Yes ENO negative results found Ova Ma
Please summarize any negabve results from the database searches indicated above: BUTTERRY TRUST:
Negative Media: MI negative media pertains to a company called the Butterfly Trust in Europe. This is not our client. Our client is an actual bust created by
a Grantor and not a company.
No cowl cases
JEFFREY EPSTEIN:
Previously approved KYC 1:01082293 8 01121718
Al negative media pertains to court cases which have been previously approved in the above mentioned KYCs.
Court Cases have been closed
D RDC alerts for Richard Kahn came up but they were all false positives as the age and locations of the alerts did not match the age and address co flle.
HARRY BELLER:
No negative media
Court case kits him as a defendant for being chief of medical staff for Jackson Memorial Hospital. The court concluded that the plaintiff had no cognizable
claim that his crvil rights has been isolated, but refused to &miss his complaint as to his antitrust clam Defendants' motion was thus granted In part and
denied in part. The defendants listed in this case have not committed any Siegal acts of conduct in any way. The case was settled on 6/30/1987.
ERIKA KELLERHALS:
No negative media
Enka is an attorney and lsted as legal counsel for several court case. Court case to appeal from a decision of the bankruptcy court Appelke trustee moved
to dismiss the appeal for failure to prosecute under Fed R. of the six Poulis factors, Rye weighed in favor el dismissal and it was granted. Another court case
for dissolving of marriage and property settlement. The case was concluded.
E. To the best of your knowledge, has the client ever been convicted of a crnsinal offense? @Yes O No
To the best of your knowledge, has the customer ever been involved in any past litigation against
F Deutsche Bank AG or any of its subsidiaries or is the customer threatening Itpotion against
Deutsche Bank AG or any of cis subsidiaries? (11 yes, inside &tat& below and contact Qtuky Mgt OYes 2 No
(tsar/1AM tate Regulatory Control Group and noo5' arnplianeelmnectistey)
Does the client or related party have any financial or other association / Interactions within
G.
countries or regimes sanctioned by the Office of Foreign Assets Control (OFAC)? OYes 2 No
Does the client or related party have any femoral or other association/ interactions within high risk D yes 2 No
H.
countries?
I. Corporate Documentation Attached (Legal Entitles Only) 2 yes El No ONot Applicable
SONY_GM_00039995
hups://dbforcepb.my.salesforcaaNtEIDEgthiLIJIA10000000D9Di&e... 7/30/2019
CONFIDENTIAL - PURSUANT TO FED.R CRIM. 6(e) DB-SDNY-0002819
EFTA_00150604
EFTA01284082
KYC Print Page 12 of 14
J. Undisclosed Principal Form Compete (Intermediaries OnlY) CI yes D No WINot Applicable
K. if Lexis/Nexis Search Results, Corporate Document or Other Supporting Documentation s not in English, please provKle an English summary of the
nature/contents of the non-English Documentation:
1. Special Risk Factors
Does the account have Nexus to Special Risk Countries' O Yes E No
Is the account structure unusually complex?
Ores
E
No
Is there any Indication the client set up a non operating company expressly O yes
for the purpose of transfeMng shares to third parties' a No
Is there any Indication this cold be a prohibited business relationship' CIYes E No
Are the bearer shares identified subject to acceptable controls' Dyes EN*
SDNY_GM_00039996
littps://dbforcepb.my.salesforcaraNtEIDrhilidiA14000000D9Ditice...
ℹ️ Document Details
SHA-256
e512332e767d2c6a1e530ca3f744aaf4afc78e90d8b725a4b740696050574a1d
Bates Number
EFTA01284072
Dataset
DataSet-10
Document Type
document
Pages
14
Comments 0