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EFTA01283800.pdf
AI Summary
This document is a Deutsche Bank Know Your Customer (KYC) file for Jeffrey Epstein from 2013, detailing the establishment of four accounts for his companies Southern Financial LLC and Southern Trust Company Inc. It provides detailed financial information, background checks, and compliance approvals for Epstein's banking relationship, including wealth estimates and business activities. [Rating: 8/10 - High-profile figure's detailed banking documentation revealing financial structure, wealth sources, and bank compliance processes during period of scrutiny]
Flags
notable_figures
financial_transactions
witness_testimony
legal_proceedings
Extracted Entities
| Name | Type | Context |
|---|---|---|
| US Virgin Islands | location | Epstein's country of residence and location of business entities |
| Bear Stearns | organization | Where Epstein began career as options trader in 1976 |
| Deutsche Bank | organization | Bank conducting KYC review and opening accounts |
| JP Morgan | organization | Previous financial institution where Epstein held $20 million in assets |
| Southern Financial, LLC | organization | Epstein-controlled entity opening accounts at Deutsche Bank |
| Southern Trust Company, Inc. | organization | Epstein-controlled entity described as consulting services company |
| Brian M. Biggar | person | Deutsche Bank Office Director who approved the accounts |
| Chip Packard | person | Deutsche Bank AML Compliance officer who cleared background alerts |
| Jeffrey Epstein | person | Main account holder and sole shareholder of entities, described as self-employed with estimated net worth of $100-500 million |
| Leslie Wexner | person | Identified as Epstein's only non-anonymous client |
| Paul Morris | person | Deutsche Bank relationship manager who previously worked with Epstein at JP Morgan |
Full Text
KYC Print Page I of 12 DB PWM GLOBAL KYC/NCA: PART A KYC Case • : 01082293 Status : 6. Approved One sheet must be established per relationship - list all accounts included in the relationshi 1. Relationship Details Relationship Nanw: EPSTEIN, )EFVREY REtATTONSHIP:00000013290 Booking Center: New York Relationship Manager: Paul Morns g New PWM Relationship O Exiting PWM Relationship Relationship to PWM: If distirv, please indicate sing when the relationship exists, provide reason for new profile and attach old profile: O Client Referral El RN Prospect O Intermediacy/BM O Other Source (CIB, etc.) How Was the Client(s) Introduced) How long has the RM peisonaNy known the Please provide details (e.g. amt of referral source, how many years RM personally has known client, etc.): Jeffrey Epstein was client? a client of Paul's at JP Morg n. Paul end Jeffrey Epstein had a mutual friendff °league olio introduced than while Paul was at JOMorgan. Over the course f a few meetings Paul was able to et Jeffrey to bring some of his funds over to JPMorgan Does Deutsche Bank pay a U Yes I g No retrocession or similar compensation to a third party ful for the introduction of this Ycs, descrtbe): retallaishp? List all existing and new accounts brayed in this relationship Legal Ertty Account Name / Number Opening Date (intended/actual) Account(s) 1 2 Southern Frnanclal, LLC 8/19/2013 2 g Southern Financial, LLC 8/19/2013 3 2 Southern Trust Company, Inc. 8119/2013 4 2 Southern Trust Company. Inc. 8/19/2013 Who is he Orrery contact person or the RM? (Note: This Preferred method of contact person needs to have Jeffrey Epstein 390 775 2525 (ein-mdiacial te phone no, fax no., signatory rights and/or address, etc.): kiloimation right for the accounts.): SDNY_GM_00039691 https://dbforcepb.my.salesforCCINBIDaiLIJIAL000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002515 EF1'A_00150300 EFTA01283800 KYC Print Page 2 of 12 One sheet mint be established for cads account to be opened 2. Account Ownership Summary Account Name: Southern Financial, LLC Acct. Number (da vadable). Account Manager: Paul Morris What is the purpose of the account (e.g. portfolio management, advisory account, custody services, longterm investment, payment/expense account)/ Money Market. To hold funds for the company. Indicate from ',Mere the assets are expected to lain? DB 0 Group: Same Booking Center (Skate account number): 0 DO Group: Other Booking Center (indicate DB location and account details): J Other Institution (Indkate name & locatIon) rblorgan, NYC 0 Physical Deposits (specify cash, securities, cheques,...): What is the expected size and frequency of regular inflows and outflows for the account (indicate estimated number and volume per wonth)'r: Roughly 2 inflows & outflows per month ranging from $1000 to $10,000. I Currency I USD V/hat is the expected volume of assets and currency for the account approx. 90 days after opening' 1 50' What is the expected volume of assets and currency for the account approx. one year after opening? 1150,000 'Currency I USD DoesAvIt the client have Assets Under Management (AuM) within DB under Fur. 3M7 • Yes 74No Please list all parties related to the account. for each party: • heck d a source of wealth escription is required for the party. • Check the appropriate hex l describe the relationship of the party to this account (> 1 can be selected). • I non i or the check boxes pply, describe the party's relation t the arrow* in the "Others column. • Many deS(nbe the relation hip between the parties in the last column. • lease drill down to the ultirnateiunderlying Elentikuil Owner(s). Anal Descrytnn AccountPIC Settler of Arnie ‘SignatoryslmItedrInancial Significant -eftill aantor/Settlorf-oundinOther Entityul Source Holder Owneffnist / Bent/Make FA 'OA IltennedlasyStiateitolderltepresentattve Donor please of Wealth Founder of Ownw ?OA (FIN) ,> • 25%) *scribe required Foundation Non-PIC ather roles entity and/ix Parties 'Indicate ndicate related to ownership dationship his %) aetween account sorties) Sole I matey 0 0 0 0 0 0 0 0 0 0 0 1 EPStekl 0 of Southh/ern Trust: Southern 2 El 74 Financial H NI D 0 El • 0 0 0 0 LLC Southern Trust is the sole rnenter of Southern Southern Trust 3 Ea Company, • • 0 0 0 0 0 No 0 0 0 F an in d a n J c e i f a fr l e y Inc Epsten is he sole shareholder 3f Southern Trusl SONY_GM_00039692 https://dbforcepb.my.salesforeCCINErilicardiAL000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SONY-0002516 EFTA_00150301 EFTA01283801 KYC Print Page 3 of 12 2. Account Cnynerahlp Summary Account Name: Southern Financial, LLC Acct. Number Ofa vailable) Account Manager Paul Morns What is the purpose of the account (e.g. portfolio management, advisory account, custody services, tong-term investment, payment/expense account)' Chocking account to hold funds for the corrpany. Indicate from where the assets are expected to ankte? O De Group: Same Booking Center (indkate account muter): O DO Group: Other Booking Center (indicate DB location and account details): 2 Other Institution (Indicate name & locationk 'Morgan, NYC O Physkal Deposits (specify cash, securities, cheques, ...): What is the wetted size and frequency of regular inflows and outflows for the account (indicate estimated number and volume per month)': Roughly 10 Slows and 10 outflows per month ranging from $1,000 to $10,000. I Currency I What is the expected volume of assets and currency for the account approx. 90 days after opening? 150' USO What is the expected vc4urne of assets and currency for the account approx. one year after opening? 1100,000 I Currency I USD Doe/wi the client have Assets Under Management (AuM) witNn DI3 under Eur. 3M? • Yt5 a N3 Please Ilst all perdu related to the account For each party: • Check I a source of wealth description Is required for the party. • Check the appropriate box to describe the relationship of the party to thts account (> 1 can be selected). • If none of the check boxes apply, describe the party's relation t the account in the 'Other" cobra. • Always describe the relationship between the parties In the last column. • Please dill down to the ultimate/underlying Beneficial Owner(s). -egaliDescrptbn AccounbalC Senior of Jitimate ISignatorysimitectinancial Significant _eget 'rantortSettiorrounding Other Entityof Source Holder DernerTrust / 3enefirialor FA POA IntermediarySharehokterReprmentative Donor please of Wealth Founder of Owner POA (FIM) ,>=25%) Jesuitic required Foundation Non-PIC idler roles entity and/or Parties ,indkate ndicate related to ownership elmionship this %) ketween account sorties) Sole .1c4frey f—i O • O O O • O • shareholder 1 • a Epstein " I o of SSoouuthern Trust; Southern 2 5r41 Ea tlnancial a O O O O O O O O O LLC Southern Trust is the sole "verdict of Southern Southem 2 2 Trust O Financial 3 Company, • O O O O O O 100 O O and Miley Inc. Epstein is the sole shareholder of Southern Trust SONY_GM_00039693 https://dbforcepb.my.salesfonCINErilEalidiAL000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED_ R_ CRIM. P. 6(e) DB-SDNY-0002517 EFTA_00150302 EFTA01283802 KYC Print Page 4 of 12 2. Account ownerablp Summary Account Nano: Southern Trutt Company, Inc Acct. Number (/avolitakt. Account Manager Paul Morris What is the purpose of the account (eg. portfolio masa ement, advisory account, custody services, long-term Investment. Payment/expense account)' Checking account. To hold funds for company Indicate from item the assets are expected to mho, O De Group: Same Booking Center (Indicate account miter): O DO Group: Other Booking Center (Indicate DB location and account details): 2 Other Institution (Indicate name & location )fliorgan, NYC O Physkal Deposits (specify cash, securities, cheques, ...): What is the expected size and frequency of regular inflows and outflows for the account (indicate estimated number and volume pe month)?: Roughly 10 Felons and 10 outflows per month ranging from $1,000 to $10,000 50000 I Curraby I USD What is the expected volume of assets and currency for the account approx. 90 days after opening' I ' What is the expected volume of assets and currency for the account approx. one year after 1100,000 I Currency I USD opening' Dobjwil the client have Assets Under Management (AuM) within 06 under Eur. 3M? . YES 4 No Please llst all parties related to the account For each party: • Check I a source of wealth desalptka Is required for the party. • Check the appropriate box to describe the relationship of the party to this account (> 1 can be selected). • If none of the check boxes apply, describe the patty's rebtbn to the account in the 'Other' cokenn. • Aierays describe the relationship between the parties in the last column. • Please drill down to the ultimaterunckrlying Benefaial Cornet) -egallDescrotbn AccounbalC Senior of Jkimate SignatornbatedFinancial Significant _eget GrantoriSettlorrounding.3ther [mayor Source molder DwnerTrust / 3endiciakor Rd POA InterrnediarySturreholdertepresentative Donor please of Wealth Founder oflymer POA (F1M) ,>=25%) describe requied Foundation I Non-PIC other roles entry and/or Parties ,ndkate miaow related to ownership Mationship it %) etween MUSKS mrties) Sole Jeffrey i, • • shareholder 1 lil El Epsteb O A O O O O O of Southern inn; SOUh em O 2 E?I Innt O • O O O O U 2 (-7i O _ompany, enC- SONY_GM_00039694 https://dbforcepb.my.salesforcCLINErilDEgclardiAL000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DS-SONY-0002518 EFTA_00 150303 EFTA01283803 KYC Print Page 5 of 12 2. Account Ownership Summary Account Name: Southern Trust Company, Inc. Acct. Hunter ru'avalitbki. Account Manager Paul Monis what is the purpose of the account (e.g. portfolio management advisory account, custody services, long-term Investment, payment/expense account)? Money Market account. To hold funds for the company. Indicate from vdiere the assets are expected to arrive? O De Group: Same Booking Center (indkate account number): O DO Group: Other Booking Center (Indicate DB location and account details): 2 Other Institution (Indicate name & location )(Morgan, NYC O ',tyska! Deposits (specify cash, securities, cheques, ...): What is the expected size and frequency of regular inflow and outflows for the account (indicate estimated number and volume per month)?: Roughly 2 inflows & outflows per month ranging from $1,000 to $1&0)0 54" I Currency I USD What is the expected volume of assets and currency for the account approx. 90 days after opening' I What as the expected volume of assets and currency for the account approx. one year after 1150,000 I Currency I USD opening" 5 No Does/will the client have &wets Under Management (AuM) YAW 013 under Eur. Ma 0 Ym Please Ilst all parties related to the account For each party: • Check I a source of wealth desalption is required for the party. • Check the appropriate box to descrte the relationship of the party to this account (> 1 can be selected). • If none of the check boxes apply, describe the party's relation t the Kona* in the 'Other column. • Always describe the relationship between the parties in the last carton. • Please drill down to the ultimate/underlying Benetkial Owner(s). -egaliDesattbn Accoun0PIC Senior of Jltimate ISignatorytimitedrinancial Significant AO Grantor/Settlor-ounding ather Enteral Source Holder DvmerTrust / Seneficiabr Fiji POA IntermediareShareholdergepresentathe )onor 'please of Wealth Founder of Owner POA (FPM) ,>•25%) iescribe required Foundation Non.PIC ,the roles entity and/or Patties ,Indkate Mimic related to ownership rIationship .his %) >E4Weel account lathes) Sole 1 El 0 E J p e s ff treeny m • • O N O O O O O o sh f a S r o e u h t o hlderenr Trust; Southern O O 2 21 Tnnt r-7, • O O O O • O 2 Company, Inc. SONY_GM_00039695 https://dbforcepb.Illy.salesforeCLINErilDaaTIAL000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SONY-0002519 EFTA_OOI 50304 EFTA01283804 KYC Print Page 6 of 12 One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summary 3A. Individual Details (for all parties) Individual's Name: Jeffrey Epstein - 00000983289 Date of Birth: 1/20/1953 Country of Residence: USVI Canby of Ckizenship: USA Has client resided outside of Address d panary residence: Utte Saint James Saint 'Tomas 00802 US Virgin Islands his/her countryof alionalay O yes ®No fix 5 yeas or more' Profession/Occupation: Self Empolyed Tax ID / SSN: 090443348 Current Employer: Southern FbanclaILLC PosItionfiltle/Ranic President Address of engeoYer: 6100 Red Rook Quarter B3 St. Thomas USVI 00002 Does the person work as senior executive of a DB-recognized regulated entity in the financial %tubs,' or an entity listed on a D8-recognised exchange' (Not applicable for operating entItia • Y es R1No Is the indwidual a Politically Exposed Person (PEP)'/(if Yes, desctibe) O Yes RI No To the best of your knowledge, is the individual related to an en-pewee of the DB group7(lE O Iambi O Friendship 21N one Family or Friendship, *seine) To the best of your knowledge, Is the individual party to a non-banking relationship with WIND Deutsche Bank (e.g., external legal counsel, client referral source, supplier of goods or Oyes services)70/ Yes,describe) Indicate where and when the client meeUng(s) took place: II applicable, indicate Wien bank officers have met the person: Client Private Client Place of Bank Officer Name(s) Bank Office: Other location (specify): Date: Dominic: Business: Paul Morris O O 21 4/3/2013 O • O O II D • Wealth Details for des Individual are not Ailed in, because they are the same as for the following person: 3B. Wealth Details (Only for parties regulnng 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' Pnrnary industry of source of Vieata/Source of Funds" Summarize Source of Wealth: W Business Owner il Salary/Earnings 0 Investment U Inhartance/Gifts O Other: Further Describe Source of Wealth /Detail the history of wealth for each of the sources: (e.g. For trusts, how did settler accumulate wealth' For inheritance, how did family accumulate weakh,For business owners, how long in business, how many ark:40%es, level of profitability' Indicate type of business, countries of mayor activities, Important business partners.) Epstein began his financial career in 1976 a an options trader at Bear Steams and became a panned n 1980. In 1982, Epstein founded his own financial management firm, J. Epstein & Co., managing the assets of clients with more than a bans n 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. AI of his dents were anonymous except for the very wealthy businessman Leslie Wexner. His wealth has come from his days at Bear Steams and his financial management firms Estimated Annual Inmost-(S): 10,000,000.00 Estimated amount of investable assets(f): 550 Mb - 100 Mb Estimated Net Worth($): $100 MM • 500 MM Amount of assets planned to invest with PW14($): 10,000.00 Other Known Financial Institutions: Institution: .IPMargan Country: USA Est. Assets Under Mgt: 20,000,000.00 Institution: Country: Est. Asses Under Mgt: SDNY_GM_00039696 https://dbforcepb. y.salesforeC6CINErilDaatiAL000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002520 EFTA_00I 50305 EFTA01283805 KYC Print Page 7 of 12 Insteutian: Country: Est. Assets Under tint: Please Indicate the farttly situation of the individual (marital status, othe family members. etc.): Single One sheet must be established for EACH LEGAL ENTITY in Section 2. Account Summa 3C. Legal Entity Details (For all Legal Entities) Legal Entity Name: Southern I-manual MC • 00000483887 Ire Private inveramon O O foundation/Association ❑E l Trust RI Company . Estate Type of Dstity: Purpose Entity: 1C—.•j Partnership of Philanthropic/amniaMe O Commercial Type of Entity Other (specify): PUtp0Se of Entity Other (specify): Country of US Vagin Islands Date of Intorporaton / 2125/2013 incorimatiolvregivration: registration: Vokker Status: VWcker Flag: Address (city, street, 'nisi 6100 Red Hook Quarter 83 St Thomas 00802 US Virgin Islands U.S. TIN/EIN: 66-0799192 code). Provide a description of the entity's organizational structure, its ownership structure and Its Top Management. For trusts/ mindations, Include Information about reexabillty,settior and beneficlarlesetc.: Southern Trust Company Inc is the sole member of Southern FittaIldill LLC. Jeffrey Epstein is the sole shareholder of Southern Trust Company Inc Please indicate how ownership of the legal entity is reflected: Southern Trust Company Inc Is the sole member of Southern Financial LLC. )effrcy Epstein is the sole shareholder ot Southern Trust Company Inc II Special attention: Bearer Shares' Indicate where shares are custcdied: Describe the chain from the direct owner of the entity to the ultimate beneficial owner afoot the same persons) Southern Trust Company Inc Is the sole member of Southern Financed LLC. Jeffrey Epstein is the sole shareholder of SOW/1CM Trust Company Inc To the best of your knovdedge, is the entity party to a non-banking relationship with Deutsche Bank external legal counsel, client referral source, SuPpeer of goods or servkesp: Yes O No @ Describe Nature of Entity's Primary Business and Investment Activities This business Is funded by Jeffrey Epstein's wealth. This company was formed to hold fir. Epstein's personal wealth ark' invest In deferent ventures.This company invests in real estate, Nature of the business: equities, commodities, etc and gels its revenue from the gains it makes in these investments. It 6 a company formed to Invest the assets of M. Epstein Countries velem business Is transacted: US Virgin Islands Number of employees: 3 3D. Wealth Profile (Only for parties requiring source of wealth description es indicated in Section 2) Primary Country of source of wealth/source of funds? Primary Industry of source of Wealth/Source of Funds? Provide Evidence of Corporate Assets (e.g. balance sheet or equivalent sum-nary of assets: kabilities). The meal funding in February 2013 was $1,000 from the sole shareholder of the sok• ellanai'm immber (leffrry Epstein). Estimated gross receipts pa.(3): 2,000,000.00 Estimated net prom p.a. (5): 1,540,000.00 Estimated investable assets (5): 41 MM Potential Amount to be invested with PWM ($): 300,00000 Other Known Financial Institutions: Institution: intiorgan Country: USA Est. Assets Under Mgt: 1,000,000.00 Institution: Country: Est. Assets Under Mgt: SDNY_GM_00039897 ps://dbforcepb.my.salesforcaraNEJIDEschilidiAL000000D9Ditice... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002521 EFTA_00150306 EFTA01283806 KYC Print Page 8 of 12 Institution: I I Country. Est. Assets Under Mgt: One sheet must be established for EACH LEGAL ENTITY in Section 2. Account Summa 3C. Legal Entity Details (For all Legal Entitles) Legal Entity Name: Southern Trust Company, Inc. - 00000403883 J Private Investment O O Foundabon/Association O Trust @Company O Estate Type of int Ily: Purpose of Entity: Philanthrodc/Chaeitable O • Partnership COMMerCL31 Purpose of Entity Type of Entity Other (specify): Other (specify): Country or US Vegan Islands Date of incorporation / 11/18/2011 IncorporatlotVregistration- registration: Volcker Status: Volcker Flag: Addries(city, street, post 6100 Red Hook Quarter EC St Thomas 00802 US Virgin Islands U.S. TIN/EIN: 660775861 code): Provide a description of the entity's organizational structure, Its ownersNp structure and its Top Management. For trusts/foundations, Include hformatton about tevocablley,settke end bendklariesietc.: Please Indicate how ownership of the legal entity is reflected: Jeffrey Fustein b sole managing member MI special attentbm Beater Shares - Indicate where shares are cintodied: Describe the chain from the direct owner of the entity to the ultimate beneficial owner Of not the same persons). Jeffrey Epstein is sole managing member To the best of your knowledge, i.. the entity party toe non-banking relationship with Deutsche yes O No Eil Bank (e.g. external legal counsel, client referral source, soppier of goods or services)?: Describe Nature of Entity's Primary Business and Investment Arthritics Consulting Services relying on Financial and Bietnedkal algorithms. Southern Trust is a private consulting company that invests the assets of their dents and gets their revenue from the return Nature of the business. of these Investments. Southern Trust invests in deferent portfolios catered to their clients and makes their revenue based on the returns and the fees associated with managing their clients tassels Countries Mere butineSS is transacted: US Virgin Islands Number of emprk>yees: 4 3D. Wealth Profile (Only for parties requirim since of wealth descnption as indicated in Section I) Primary Country of source of wealth/source of Funds? Primary industry of source of Wealth/Source of Funds, Provide Evidence of Corporate Assets (e.g. balance sheet or equhtalent summary of assetsflabilities): Consult and invest dent funds and gain revenue based on fees and returns I somated gross receipts p.a.($): 2000,000.00 I stirnated net profit p.a. (5): 1,500,000.03 Estimated investable assets ($): 52 MM - 5 MM Potential Amount to be invested wish PWM ($). 300.000.00 Other Known Einem al Institutions: Institutacfr .IPPlargan Country' USA Est. Assets Under Plot: I OCO 003 00 InStitutton! I ountry: Lst. Assets Under Mgt: Institution: Country: 1st. Assets Under Mgt: SDNY_GM_00039698 ps://dbforcepb.my.salesforca:tNEJIDLNIIIAL000000D9Ditice... 7/18/2019 t CONFIDENTIAL - PURSUANT TO FED R CRIM. P. 6(e) DB-SDNY-0002522 EFTA_00150307 EFTA01283807 KYC Print Page 9 of 12 DB PWM GLOBAL KYC/NCA: US/LatAm/Inel PART B Relationship Name EPSTEIN, JEFFREY RELATIONSHIP Risk Rating Comments: Booking Center 12 NY O Oq Offshore IP ii'dgrate 121High Risk _.I NY/Offshore isk (Compliance Signature) O 08 Employee O DB Managed PIC O DO is Trustee/Co-Trustee O Beams Shares 4. Attachments A. Type of Photo ID Provided EnD rivers License R Passport O National/State ID O Other Checklist of names (individuals and/or entitles) that were submitted for database searches is B. attached 21y es O No C. Please indkate the results of the database searches performed RDC searches complete ®Yes O Ho negative results found Ryes O110 PCR checks complete 'a yes O No negative results found n Yes O No OFAC checks complete Oyes O No negative results found ales ®No BIS searches complete (Lexis/Neds, Facilva, Reuters, Dow Jones, D&B) ®yes Otio negative results found Oyes No Denial Orders checks complete Ryes ONO negative results found Oyes Olio Martindale-Hubbell searched (Lawyers/Law Firms only) aka R Ho negative results found • yes • No Please summarize any negative results from the database searches Indicated above: JEFFREY EPSTEIN: ROC Alert a I •- Cleared & APPROVED by Chip Packard, AM. Compliance, and Pat Harris PCR Alert 91/2 — Not ow client Al Cases Closed SOUTHERN FINANCIAL 1.1e. No negative media No court cases SOUTHERN TRUST INC: No negative media Court Case -- Not our dent. FINANCIAL INFOMATICS INC: No negative media No Court CaseS I. Epstein & Co. Al Negative Media is our client He has been clears of posing a reputational risk as shorn, by the Alt Clearance attached Court Cases have been closed FINANCIAL TRUST &CO RDC/PCR alert is associated with Southern Financial, the company 4 merged into. This alert has been cleared by Compliance and is attached Court Cases Me closed E. To the best of your knowledge, has the client ever been convicted of a criminal offense? El yes O No To the best of your knowledge, has the customer ever been invotred in any past litigation against Deutsche Bair AG or any of Its subsidiaries or Is the customer threatening Illigabon against F. Deutsche Bank AG or any of Its subsidiaries? (If Yes, provide cklaia IX1011* and conbct Quallty Mgt OYes ®1b (Lst.AnYlneVor the Regulatory Cot Group indoor:1y Compliance irnmediately) Data the dent or related pa have any financial or other association / Interactions within countries O yes g No G. or regimes sanctioned by the Office of Foreign Assets Control (OFAC)? Does the dent or related party have any financial or other association/ Interactions vdthin high risk . mesa No H. countries? I. Corporate Documentation Attached (Legal Entities Only) 121 yes O No ONot Applicable SDNY_GM_00039699 https://dbforcepb.my.salesforceLINErilDnEglardiA1000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SONY-0002523 EFTA_00150308 EFTA01283808 KYC Print Page 10 of 12 I. Undisclosed Pnnopal Form Complete (Intermediaries Only) li yes D No rI Not Applicable K. If Lechtfieds Search Results, Corporate Documents oc Other Supporting Documentation is not in English, please provide an English summary of the nature/contents of the non-English Documentation: L. Specal Risk Factors Does the account have Nexus to Special Risk Countries? Ores ®No Is the account structure tnusually complex) OYes ®No I f s o r t h th e e re p a u n rp y o i s n e d i o c f a t t i r o a n n s th fe e r c m lie g n s t h s a e re l u s p to a t n h o ird n o p p a e rt r i a e t s in ' g company expressly l e _ n l Yes RHO Is that any indication this could be a prohibited business relationship> O yrs 21W tut the bearer shares identified subject to acceptable controls' IN Yes &I No SDNY_GM_00039700 ps://dbforcepb.my.salesforCCINErili.ardiAL000000D9Ditice... 7/18/2019 t CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0002624 EF1'A_00150309 EFTA01283809 KYC Print Page 11 of 12 M. Case Comments records to display. ONSHORE APPROVALS Client Facing Professional (CFP): Paul Morris Signature) 7/17/2013 )atil Morris Office Director/Business Head: Brian M. &agar Signature) 1118/2013 ,Loan M. Biggar Regional Office Director: Signature) Mt Business Risk: (Signature) Armen Brash Armen Brash 8/20(2013 AML Compliance: (Signature) Janice Franklin lance Franklin 8/21:2013 LATAN /INTERNATIONAL APPROVALS Olent Fadeg Professional (CEP): (Signature) Account Manager: (Signature) Global Market Team Head (Signature) STMTH)/Sub-Market Team Head 94TH): Mt Business Risk (Signature) Mt Compliance: (Signature) PRIVATE WEALTHM ANAGEMENT POLICY STATEMENT: Deutsche Bank Private Wealth Management (PWM) worldwide is committed to professionally serve the interests ofi ts clients. To do so. Client Facing Professionals!(!) (CFP 's) should establish and maintain business relationships onty with persons who satisfy our high standards of suitability. background and character. Due diligence obtained on the client must be appropriately documented by the CFP. It is the responsibility ofC FP's to demonstrate that they blow their client both at the inception ofa relationship and on an ongoing basis. DECLARATION FOR ALL SIGNERS OF THIS FORM: To the best ofm y knowledge and belieft he 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 oft he client(s) and that! have followed all the procedures relating to account opening as described in the PWMA mericas Procedures and the PIMGlobal KYC Policy (I) Client Facing Professionals (CIF's) include: Relationship Managers, Wealth Ativisurs. Product Officers, Brokers, Client Managers. etc. Deutsche Bank Americas New York SDNY_GM_00039701 Ilttps://dbforcepb.my.salesforCCINBICIaallAL000000D9Ditice... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002525 EF1'A_00150310 EFTA01283810 KYC Print Page 12 of 12 SDNY_GM_00039702 https://dbforcepb.my.salesforCCINErilDrairdiAL000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002526 EFTA_00 I 503 I EFTA01283811