EFTA01385146.pdf

Business Line US Onshore GCIS # / KYC # 575969/01898372 New or Existing Existing relationship since 8/26/2013. A total of 30 deposit accounts and 3 mon Relationship? market accounts for multiple entities, 5 brokerage accounts and 1 custody acct If yes. please include Total AUMs $224mn. relationahip since date. approx tl of accounts. AUM. etc.) Legal name of Account The 2017 Caterpillar Trust Holder(s) Name of UBO(s) Jeffrey Epstein (Please include UElOs who own 25% and more; If there are multiple layers, please include description of ownership structure) Description of Type of We are opening a deposit account for The 2017 Caterpillar Trust. The account • account being opened used to pay annual annuity payments with detailed purpose of the accounts (Please include SOW information/ Geographic location/ For Entity Accounts: Description of the entity and background information on the IRO) Reason for High Risk This relationship is deemed high risk due to multiple court cases on Jeffrey Eps involving 22 April 2004 SEC filed a settled civil fraud action for illegal insider tra three publicly traded Massachusetts banks. Final judgement permanently enjoii from violating the antifruad provisions and he agreed to pay a total of $72532.0£ disgorgement of trading profits, prejudgment interest and civil penalties. Epsteir sentenced to 21 months in federal prison for three counts of fraud, sexually ass a girl and solicitation of prostitution. These alerts were previously approved by management and AML Compliance. Prior clearance is attached as a reference PEP (Y/N) Yes, close affiliation to Bill Clinton and Prince Andrew If yes. include details Any negative media Yes and/or court cases? Include ALL negative media court cases If Yes, please give Aside from the court cases listed in the reason for high risk, all other alerts were details 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 the for the relationship not see a reason to discontinue the existing relationship with Jeffrey Epstein. despite High Risk Factors CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0086237 CONFIDENTIAL SDNY_GM_00232421 EFTA01385146