← Back to Browse
EFTA01283985.pdf
AI Summary
This document contains Deutsche Bank's Know Your Customer (KYC) application for Jeffrey Epstein's Neptune LLC accounts, detailing his $200 million transfer from JPMorgan in 2013 to fund his NYC home operations. The document reveals Epstein's financial structure, estimated net worth of $100-500 million, and authorized signatories including attorney Darren Indyke. [Rating: 9/10 - Reveals detailed financial information about Jeffrey Epstein including massive asset transfers, business relationships with major banks, and his financial network structure including previously unknown details about his wealth sources and business operations]
Flags
notable_figures
financial_transactions
legal_proceedings
Extracted Entities
| Name | Type | Context |
|---|---|---|
| Bear Stearns | organization | Where Epstein began his financial career as options trader |
| Deutsche Bank | organization | Bank opening accounts for Epstein's LLC |
| J. Epstein & Co. | organization | Financial management firm founded by Epstein in 1982 |
| JPMorgan | organization | Previous bank holding $200MM of Epstein's assets being transferred |
| Neptune LLC | organization | Single-member LLC owned by Epstein for NYC home operations |
| Southern Financial LLC | organization | Listed as Epstein's current employer where he serves as President |
| The Financial Trust Company | organization | Renamed version of Epstein's firm based in US Virgin Islands |
| Darren Indyke | person | Attorney and authorized signer being added to accounts |
| Harry Beller | person | Accountant listed as primary contact with signatory rights |
| Jeffrey Epstein | person | Primary client with estimated net worth $100-500MM, transferring $200MM from JPMorgan |
| Leslie Wexner | person | Mentioned as Epstein's only known non-anonymous client |
| Paul Morris | person | Deutsche Bank relationship manager who previously worked with Epstein at JPMorgan |
Full Text
KYC Print Page I of 13 DB PWM GLOBAL KYC/NCA: PART A KYC Case : 01195153 Status : 6. Approved One sheet must be established per relationship - list all accounts included in the relationship 1. Relationship Details Relatioreship Name: SOUTHERN FINANCIAL RELATIONSHIP:00000483290 Booking Center: New York Relationship Manager: Paul Morris q New OWN Relationship Existing PWM Relabonslup Relabonship to PWM: If existing, please indicate since when the relationship exists provide reason for new profile and attach old profile: Update of approved KYC 01135524 to add Darien Indyke as an authorized signer. Darien has been approved in KYC $1133377 ■ Client Referral 121 RN Prospect q IMennediary/FIM q Other Source (Cm, etc.) How Was the Client(s) Introduced? Now long has the please provide details (e.g. name of referral source, ow many years RM personally h s known cknt, etc.): Jeffrey Epstein is RM personally known the a current dent or the Bank. Wants to open a new account. Introduction details of Pa I and Jeffrey: Jeffrey Epstein was a client client' of Paul's at JP Morgan. Paul and Jeffrey Epstein had mutual friend/colleague who Introduced them while Paul was at Jfkorgan. Over the course of a few meetings Paul was able to get Jeffrey to frog some of his funds over to Deutsche Bank Does Deutsche Bank pay a q Yes I q No retrocession a similar compensation to a third party for the introduction of this (if Yer, descrier) relationship' List all existing and new accou is involved in this relationship Legal Entity Account Name / Number Opening Date (intended/actual) Account(s) 5 1 Neptune LLC 10/16/2013 2 5 Neptune LLC — Money Market 10/16/2013 Who is the primary contact person for the RM? (Note: Preferred method of contact This person needs to have Harry Seiler (emaial te phone no., fax no., signatory rights and/or address, etc.): wformabon right for the accounts.): SDNY_GM_00039898 https://dbforcepb.my.salesforCCINErilatitruJiA10000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002722 Erl'A_00150507 EFTA01283985 KYC Print Page 2 of 13 One sheet must be established for each account to be opened 2. Account Ownership Summary Account Name: Neptune LLC Acct. Number Acaseallablei Account Manager: Paul Morris What Is the purpose d the account (e.g. portfolio management advisory account custody services, Song-term investment payment/expense account)/ Checking account used for the daily needs of running Jeffrey Epstein's home In NYC. Indicate from where the assets are expected to wive/ El DB Group: Same Booking Center (indicate account number): O DB Group: Other Booting Center (indicate DB location and account details): RI Other Insbtution (Indicate name & location): 31/Morgan. New York O Physical Deposits (specwy cash, '<turtles, cheques, ...): What Is the expected size and frequency of regular Inflows and outflows for the account (IndiCat estimated number and volume per month)/: Roughly 10 Inflows and outflows per month ranging from $4000 to $10,000 I Currency I USD What Is the expected volume ce assets and currency fix the account approx. 90 days after opening/ I 110000 'Currency I USD What Is the expected volume d assets and currency for the account approx. one year after opening/ DoesAMI the client have Assets Under Management (AuM) within CO3 under Eur. 3M/ Oyes E No Please list aN parties related to the account. For each party: • Check if a source ef wealth description is required for the party. • Check the appropriate box to describe the relationship of the party to this account (> 1c an be selected). • If none of the check boxes apply, describe the party, relation to the account In the -Other column. • Always describe the relations* between the parties in the last olurm. • Please dril down to the ultimate/underlying Beneficial Owner(s). _egal5eunptien AccoundPIC Setter of Jltimate bgnatory.imitedrinanclal Significant _egal SraMor/Settket-oundincp3ther laity-ISource Holder Ownertrust/ Beneficially Full PO* Intermediary SharetiolderRepresentathre Donor (please if Wealth Founder of 3wner FOA (FIM) (> =25%) describe equired Foundation Non-PIC other toles entity and/or Parties (inckate mdicate related to ownership relationship this %) between account oarbes) 2 O O 1 El O _ N L e C ptune, q O O O O El O O 0 Ea Jeffrey rn 0 D 5 0 OM 0 i is 2 Epstein I.--J 3 O • ader a at t:3 • 0 O • O O O Darren 4 O O ndylce • • O O O O O O O • SDNY_GM_00039899 https://dbforcepb.my.salesforeCLINEr/IDEgrardiAL000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002723 EFTA_00I 50508 EFTA01283986 KYC Print Page 3 of 13 2. Account Ownership Summary Account Name: Neptune LLC — Money Market Acct. Number (ifa vailable). Account Manager: Paul Morris What is the purposed the account (e.g. portfolio manag meet, advisory account, custody service, long-term Investment, payment/expense account)/ Money Market to hold funds necessary to run the costs associated with Jeffrey Epstithis NYC home Indicate from where the assets are expected to arrive/ O DB Group: Same Booking Center finckate account number): 0 DB Group: Other Booking Center (indicate DB location and account detals): 14 other Institution (Indicate name & location): WMorgan. NYC II Physical Deports (specify cash, 'aortic., cheques....): What Is the expected size and frequency of regular Inflows and outflows for the account (indicate estimated number and volume pa month)' Roughly 1-3 mfbws and outflows per month ranging from $1,000 to $10,000 I Currency I USD What is the expected volume d assets and currency fa the account approx. 90 days after opening/ I What is the expected volume of assets and cwrency for the account approx. one year after 110.000 I Currency 11150 owning' Does/W1N the client have Assets Under Management (AuM) within Ce under Eur. 3al? O Yes M No Please Ilst aN parties related to the account. For each party: • Check de 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). • from of the check bates apply, describe the partys relation to the account in the 'Other' column. • Ahvays describe the relationship between the parties in the last olumn. • Please drill down to the vicariate/un0ertying Beneficial Owner(s) _eganescnpbcn AccountPIC Settle of _Minute Signatory imited Financial Significant .egal Srantor/Settice soundinspOther Enbtpf Source Holder OomerTrust/ Beneficially Full PO* Intermediary Sharelxilder2epresentatiue Dona (please of Wealth Founder of owner ?OA (FIM) (> =25%) describe equired Foundation Non-PIC other roles entity and/or Parties (imicate indicate related to ownership relationship this S) between account settles) 1 2 2 L"L'CmiMt' 'El O O is O DD El • O 2 O la Ejepsfftreeinf O OD Ea 21 O O O O O a • N 3 O O BHiaenrY Ill 0 • O II O II Darren is 4 O O Inclyke [JO O g O O O O • SDNY_GM_00039900 https://dbforeepb.my.salesforealNErilEardiAL000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002724 EFTA_00I 50509 EFTA01283987 KYC Print Page 4 of 13 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 Ctaenship: USA Has dent resided outside of Ltte Saint James Saint Thomas 00802 US Virgin Islands his/her county of nationality Oyes g No Address of primary residence: for 5 years or more' Professioni0ccupation: Self Empobred Tax ID / SSN: 090-44-3348 Current Employer: Southern Financial LLC Position/Me/Rank: President Address of employer: Does the person work as senior executive of a DB-recognized regulated entity In the financial ri __ fogi ndustre or an enbty listed on a CB-recognised exchange' (Not applicable for operating entitles t--i ICS W 4° Is the individual a Politically Exposed Person (PEP)'(1 Yes, desefibe) OYes g No To the best of your knowledge, is the individual related to an employee of the DB group'(/ 0 Family 0Friendship 5 None Fan* or rnencWup, desote) D To e u th ts e c h b e e s B t a o n f k y ( o e u .g r . k , n e o x w te le rn d a g l e l , e i g s a t l h c e o i u n n d s i e vi l d , c u l a ie l n p t a r r e ty fe t r o ra a l s n o a u l- r b ce a , n s k u in p g p r le e r la o ti f o g n o s o h d ip s w or it h O Yes J No services)7(1Yesodesente) If applicable, indicate which bank officers have met the Indicate where and when the client meebng(s) took place: Person: Ghent Private Client Placed Bank Officer Names) Bank Office: Other Location (specify): Date: Domicile: Business: Paul Morris El • 0 9/13/2013 O D O • • 0 0Wealth Details for this in:Mk:WI are not filled in, because they are the same as for the fdlowing person: 38. Wealth Details (Only for parties requiring source of weath description as indicated in Section 2) Nature of the Individual's Business: Private incsb,.nb Primary Country of source of wealth/source of Funds' Primary indusby of source of WealUVSource of Funds' ,._..., Summarise Source of Wears: Ki Business Owner 0 Salarygamings Rilmestment 0 Inheritance/Gels 00ther: Further Describe Source of liVealth /Detail the history of wealth or each of the soarers: (e.g. For trusts, how did senior accumulate wealth" For Inheritance, how did family accumulate wealth?For business owners, how long in business, how many employees, level of profitabilty? 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., managng the assets of 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 t on the island of St. Thomas in the US Virgin Islands. All of hi clients were anonymous except for the very wealthy businessman Leslie Wexner. Hs 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 assets(S): $50 WI • 100 MM Estimated Net Worth(S): $100 MM - 500 MM Amount of assets planned to nest with PWM(S): Other Known Financial Institutions: Institution: JPMorgan County: USA Est. Assets Under Mgt: 200,000,000.00 SDNY_GM_00039901 https://dbforeepb.my.salesforeC5CINErilEardiAL000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002725 EFTA_00150510 EFTA01283988 KYC Print Page 5 of 13 Institution' Counby: Est Assets Under Mgt: COUntly Est Assets Under Kilt PPlleeaassee indicate the family situabon of the individual (marital status, other family members, etc.): SDNY_GM_00039902 littps://dbforcepb.my.salesforcCaNEIDEschilidiAL000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R CRIM. P. 6(e) DB-SDNY-0002726 EF1'A_001505 I I EFTA01283989 KYC Print Page 6 of 13 One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa 3A. Individual Details (for all parties) IndMduars Name: Harry Beler - 00000487202 Date of Birth: S/9/1956 Country of Residence: USA Country of Citizenship: USA Has dent resided outside of Address of primary residence: 12 Gofer Drive Homey NY 10952 USA his/her country of nationality O Yes ®No for 5 years or more> ProfessoniOccupation: Accountant Tax ID / SSN: 081-52-0727 Current Employer: HBRK Associates Positlonfillie/Rank Address of employer: Does the person work as senior executive of a DO-recognized regulated entity In the financial I-, ndustry' or an entity listed on CO-recognised exchange? (Not applicable foe operating entitles Yes EIS Is the individual a Poetically Exposed Person (PEP)1(if Yes, descnbe) ElYes Ea No To the best of your knowledge, is the individual related to an employee of the DB group/if D Family O Friendship EA None Family or Friendship, descrbe) 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 lil No servIces)>0f Yesoltrate) If applicable, indicate which bank officers have met the Indicate %Mere and when the cent rreebng(s) took place: person: [lent Private Client Place of Bank Officer Rump) Bank Office: Other Location (specify): Date: Domicile: Business: Paul Morris El D P1 9/13/2013 0 O ri L..; O O 0 Wealth Details for this individual are not filled in, because they are the same as for the following person: 38. Wealth Details (Only for parties requiring source of weath description as indkated in Section 2) Nature of the Individual's Business: Primary Country of source of nealth/source of Funds' Primary indusby of source of Wealth/Source of Funds' Summarize Source of Wealth: O Business Owner O SalarwEamings OInvestment O Inheritance/Gifts 00ther: Further Describe Source of Weahh /Detail the history of wealth or each of the sources: (e.g. For trusts, how did settler accumulate wealth' For inheritance, how did ferrety accumulate wealth?For business owners, how long in business, how many employees, level of profitatility? 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 nest with PWM(8): Other Knoun Financial Institutions: InstibAion: Country: Est Assets Under Mgt: Institubon: County: Est Assets Under Mgt Institution: County. Est Assets Under Mgt. SDNY_GM_00039903 Imps://dbforcepb.my.salesforCaNtEllOalniliAL000000D9Ditice... 7/30/2019 CONFIDENTIAL — PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0002727 EF1'A_00150512 EFTA01283990 KYC Print Page 7 of 13 Please nclicate the family situabon of the individual (marital status, other family members, etc.): SONY_GM_00039904 https://dbforcepb.my.salesforeCLINErilalTdIA000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002728 EFTA_00150513 EFTA01283991 KYC Print Page 8 of 13 One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summary 3A. Individual Details (for an pastes) Indy:doors Name. Darien Indyke - 00000486405 Date of Birth: 2/19/1965 Country of Residence USA Country of Citizenship: USA Has dent resided outside of 2 Kean Court Lkingston N) 07039 USA his/her country of nationality Ilill yes to No Address el primary residence: for 5 years or more> ProfessioniOccupation: Lawyer Tax ID / SSN: 098.548596 Current Employer: Southern Financial LLC POSItiOnfilbeitinio Address of employer: 575 Lexington Ave, 4th Fl New York NY USA 10022 Does the person work as senior executive of a DB-recognized regulated entity In the financial I-1 ndustry' or an enbty listed on DB-recognised exchange? (Not appkable for operating entitles Yes OS O 0 Is the individual a Pordically Exposed Person (PEP)1(if Yes, describe) Ws No To the best of your knowledge, is the individual rented to an employee of the DB grouP>(i El F arnly O Friendship .ear None Family or Friendship, (Sage) To the best of your knowledge, is the individual party to a non-banking relationdup with RI Deutsche Bank (e.g., external legal counsel, client referral source, suppler of goods or O Yes No servIces)'( if Yesiestafre 1 If applicable, indicate which bank officers have met the Indicate where and when the c 'tot meeting(s) took place: Person: Olent Private Client Place of Bank Officer Name(s) Bank Offke: Other Location (specay). Date: Domidk: Business: • • O O O O EI O O O Weath Details for this individual are not filled in, because they are the same as for the following person: 38. Wealth Details (Only for parties requiring source of vreakh description as Indicated in Section 2) Nature of the Individual's Business: Primary Country of source of wealth/source of Funds' Primary industry of source of WeatIVSource of Bads' Surrrnarte Source of Weedy O Business Owner O SalarwEamings O Investment O Inheritance/Gifts 00thier: Further Describe Source of Wealth /Detail the history of wealth or each of the scuros: (e.g. For trusts, how did senior accumulate wealth' For inheritance, how did farmer accumulate wealth?For business owners, how long in baseless, how many employees, level of profitability? Indicate type of business, countries of major advents, important busness partners.) Estimated Annual Income(S): Estimated amount of Investable assets(s): Estimated Net Wodh($): Amount of assets planned to elitist with PWM($): Other Known Financial Institutions: Institubon: County: Est Assets Under Mgt: Institution: Country: Est Assets Under Mgt: Institution: Country: Est Assets Under Mgt. SDNY_GM_00039905 Imps://dbforcepb.my.salesforcaINEJIDLAITAL000000D9Ditice... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED R CRIM. P. 6(e) DB-SDNY-0002729 EFTA_00150514 EFTA01283992 KYC Print Page 9 of 13 Please indicate the family situation of the ndividual (marital status, other family members, etc.): One sheet must be established for EACH LEGAL ENTITY in Section 2. Account Summary 3C. Legal Entity Details (For al Legal Entities) Legal Entity Name: Neptune, LLC • 00000487269 El 676 Private Imestrnent O O FcundatIon/Asscclation O Trust Company O Estate a, Type of Entity: Entity: 0 Oq Partnersh0 rurPasea Philanthrcpic/Chantable Cornmercial Purpose of Entity Type of Entity Other (specify): other (specify): Date Country of USA incorporation// 12/21/2011 ircorporaboniregistralion: registration: Volcker Status: Volcker Flag: Address (city, street, post 6100 Red Hook, Quarter B3 St, Thomas 00802 USVI US. TIN/EDI: 4S-4093384 code): Provide a description of the entity's organizational structure, its ownership structure and its Top Management. For trusts/foundations, include information about revocablity,settior and beneficiaries,etc.: Single member LLC. Jeffrey Epstein is the sole member Mast indicate how ownership of the legal entty is reflected: O Special attention: Bearer Shares • Indicate where shares are custodied: Describe the chain from the drect owner of the entity to the ultimate beneficial owns (three the same pawns). To the best of your knowkdge, is the entity party to a non-bankng relationship with Deutsche Bank (e.g. external legal counsel, client referral source, supplier of goods or services)': Yes O No Describe Nature of Entity's Primary Business and Investment Activities This LLC was formed to held the funds necessary to cover the costs and taxes associated with Nature of the business: running Jeffrey Epstein's NYC home Countries where business Is transacted: USA Number of employees: 1 3D. Wealth Profile (Only for parties requiring 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 of Funds? Provide Evidence of Corporate Assets (e.g. balance sheet ce equivalent summary cf assets/liabdities): This LLC is funded my contrbutions made by Jeffrey Epstein. Estimated gross receipts p.a.($): Estimated net profit p.a. (5): Estimated investable assets ($): <$1 MM Potential Amount to be invested witi PWM (5): 20,000.00 Other Known Financial Institutions: Institution: JPMorgan Country. USA Est. Assets Under Mgt 20,000.00 Institution: Country: Est. Assets Under Mgt Institution: Country: Est. Assets Under Mgt SONY_GM_00039906 https://dbforcepb.my.salesforeCLINEIDEgrbadiAL000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002730 EFTA_00I50515 EFTA01283993 KYC Print Page 10 of 13 DB PWM GLOBAL KYC/NCA: US/LatAm/Int'I PART B Relationship Name SOUTHERN FINANCIAL RELATIONSHIP Risk Rating Comments: Booking Center El NY O E Offshore O Moderate mi High Risk iiacqueline Lighten:IV NY/Offshore Risk (Complenc *naafi.) • DB Employee • ce managed PIC ° DB Is Trustee/Co-Trustee °Bearer Shares 4, Attaraments A. Type of Photo ID Provided 0Drirers License 0 Passport ONatenal/State ID °Other Checklist of names (Individuals and/or entitles) that were submitted for database searches is B. attached 2 yes O No C. Please indicate the results of the database searches performed RDC searches complete 2 yes C No negative results found Eves 0 Ho PCR checks complete 0 yes C No negative results found Oyes & No OFAC checks complete 12 Yes O No negative results found Ores WI No BIS searches complete (Leds/Necis, Paden, Reuters, Dow Jones, 06B) 5 yes O No negative results found Ova RI No Denial Orders checks complete 0 Yes • No negative results found Ores El Ho Martindale-Hubbell searched (Lawyers/ Law Finns only) Oyes E No negative results found °Yes • No Please summarise any negative results from the database searches incloabxl above: DARREN INDYKE KYC approved in case #1133377 NEPTUNE LLC: See attached AML Clearance -- The RDC alert was a false hit Negative Media: All negative media is not our client. MI negative media either predates our clients formation (2011) or is another U.C. Our Neptune LLC is a single member LLC that runs the operations of a home D ' JEFFREY EPSTEIN: See KYC *01082293 and #01121718 for previous KYC approval and all pertaining documents HARRY BELLER: Negative Media: Not our client All negative media pertains to an environmental microbiologist Our client is an accountant Court Cases: a1: Deposal in 1987 Al other cases are not ow client. The other court cases refer to a Or. Harry Baer. Our client is an accountant E. To the best of your knowledge, has the client ever been convicted of a airinal offense? IO Yes O No To the best c4 your knowledge, has the customer ever been involved in any past litigation against F. D D e e u u t t s s c c h h e e B B a a n n k k A A G G o o r r a a n n y y o of f P b s s su u b b s s i i d d i i a a r r i i e e s s ? o a r i l s Y th e e s, c p u r s o t v o i m de e r d t e h a re ls a t b e e n k in w g a le n g d a c ti a o n n t a e g d a O in A s R t VIY MO. O yes 0 No asolm/Int7)or the Regulatory Control Group and notify Compoanee immediately) Does the client or rated party have any financial or other association / attractions within RI G' countries er regimes sanctioned by the Office of Foreign MSS Control (OFAC)? °Yes No 2 Does the client or related party have any financial a other asst.:tenon/ interactions within high risk D yes No H. countries? L Corporate Documentation Attached (Legal Entitles Only) 0 yes O No O Not Applicable 3. Undisclosed Prindpal Form Complete (Intermediaries Only) °Yes O No la Not Applicable K. If Lexis/Neris Search Results, Corporate Documents or Other Supporting Documentation is not in English, please provide an English summary el the nature/contents of the nomEnglish Documentation: L. Special Risk Factors SDNY_GM_00039907 https://dbforcepb.my.salesforcCUNErilDnEglardiAL000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED R. CRIM. P. 6(e) DB-SDNY-0002731 EFTA_00150516 EFTA01283994 KYC Print Page 11 of 13 Does the account have Nexus to Special Risk Countries' Oyes Ea> Is the account structure unusually complex' Dyes ENG I f s o r t h th e e re p a u n r y p o in s d e k d a b tr o a n n s th fe e r n c n lie g n s t h s a e re t 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 r I i Yes E N* Is there any indkation this could be a prohibited business relationship' CI Yes E No Are the bearer shares Identified subject to acceptable controls' 0 Yes F? No SDNY_GM_00039908 Itttps://dbforcepb.my.salesforcaINEJIDLNIIIAL000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002732 EFTA_00150517 EFTA01283995 KYC Print Page 12 of 13 M. Case Comments Created By Date Comments Jacqueline ughtbody 3/14/114 3:00 pm 1 page of DB Certificate of LLC Resolution olth the 2nd that did not list all signers, Is acceptable. The orgy revision was the 2nd page with the orrect signers that is attached separately. ONSHORE APPROVALS Client Facing Professional (CFP): Paul Morris (Signature) 2;24;2014 Paul Morns Office Drector/Business Head: Roan M Biggar (Signature) 2:24:2014 Brian Ft. Biggar Regional Office Director (Signature) AML Business Risk: (Signature) A141. Compliance: (Signature) Gwen Hill ortaio Janice Franklin Gwen Hill ci/bfo Janice Franklin 3/14/2014 Jacqueline Lightbody Jacqueline LigMbody 3/14/2014 LATAM/IRIERNATIONAL APPROVALS Client Facing Professional (CfP): (Signature) Account Manager (Signature) Global Market Team Head (Signature) (GPTOO/Subi Market Team Head .(St4T11): NIL Business Risk: (Signature) AML Compliance: (Signature) PRIVATE WEALTH MANAGEMENT POLICY STATEMENT: Deutsche Bank Private Wealth Management (PWM) worldwide is committed to professionally serve the interests ofits clients. To do so, Client Facing Professionals)( l) (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 documentedb y the CIT. it is the responsibility ofCFP's to demonstrate that they know 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 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 oft he client(s) and that I have followed all the procedures relating to account opening as described in the PWMA mericas Procedures and the PWM Global KYC Policy SDNY_GM_00039909 Ilttps://dbforcepb.my.salesforcCaNEJIDAIIAL000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED R CRIM. P. 6(e) DB-SDNY-0002733 EF1'A_00150518 EFTA01283996 KYC Print Page 13 of 13 (I) Client Facing Professionals (CFP's) include: Relationship Managers. Wealth Advisors, Product Officers, Brokers. Client Managers, etc. Dat his Book Americas New Yoh SDNY_GM_00039910 https://dbforcepb.my.salesforCCINBIDaiLIJIA10000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002734 EFTA_00150519 EFTA01283997