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 <patrick.campion@db.com>
Cc: Dana Ponzio <Dana.Ponzio@db.com>
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.)
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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.
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