EFTA01299266.pdf

Cynthia Rodriguez From: Patrick Campion Sent: Monday, February 12, 2018 4:51 PM To: Cynthia Rodriguez Cc: Dana Ponzio Subject: RE: RUSH EXCO Approval Needed: KYC Case 01898372 [Ij Classification: For Internal use only approved Kind regards, Patrick Campion Patrick Campion Managing Director I Head of Wealth Management Americas Deutsche Bank Trust Company Americas Wealth Management - Americas P rf vn 1 154-0004 New York. NY, USA From: Cynthia Rodriguez Sent: Friday, February 09, 2018 3:18 PM To: Patrick Campion <[email protected]> Cc: Dana Ponzio <[email protected]> Subject: RUSH EXCO Approval Needed: KYC Case 01898372 [II Importance: High Classification: For Internal use only Hello, I am requesting Exco Approval for a new account opening for current DB client Jeffrey Epstein. RM Name Stewart Oldfield Business Line US Onshore GCIS # / KYC # New or Existing Existing relationship since 8/26/2013. A total of 30 deposit accounts and 3 money Relationship? market accounts for multiple entities, 5 brokerage accounts and 1 custody account. If yes. please include neletionehip Total AUMs $224mn. since date. approx tl of accounts. AUM. etc.) 1 SDNY_GM_00065093 CONFIDENTIAL - PURSUANT TO FED. R.cON(F IDENTIAL DB-SDNY-0027918 EFTA_00175593 EFTA01299266  Legal name of Account The 2017 Caterpillar Trust 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 sfructum) Description of Type of We are opening a deposit account for The 2017 Caterpillar Trust. The account will account being opened be 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 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 (YIN) 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 a court cases fI 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 for the relationship do not see a reason to discontinue the existing relationship with Jeffrey Epstein. despite High Risk Factors Kind regards, Cynthia Rodriguez Cynthia Rodriguez Assistant Vice President Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 4th Fl 10154-0004 New York. NY, USA Tel. 2 SDNY_GM_00065094 CONFIDENTIAL - PURSUANT TO FED. R.QQN(E IDENTIAL DB-SDNY-0027919 EFTA_00175594 EFTA01299267  Faxi Ema 3 SDNY_GM_00065095 CONFIDENTIAL - PURSUANT TO FED. R.QP. N (F IDENTIAL DB-SONY-0027920 EFTA_00175595 EFTA01299268