EFTA01299272.pdf

Cynthia Rodriguez
From: Patrick Campion
Sent: Thursday, January 05, 2017 3:46 PM
To: Cynthia Rodriguez
Cc: Samantha Harmon; Armen Brash
Subject: RE: APPROVAL NEEDED: High Risk KYC Case 01704382 [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
345 Park Avenue. 10154-0004 New York. NY. USA
From: Cynthia Rodriguez
Sent: Thursday, January 05, 2017 1:16 PM
To: Patrick Campion
Cc: Samantha Harmon; Armen Brash
Subject: APPROVAL NEEDED: High Risk KYC Case 01704382
Importance: High
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 21 deposit accounts and 3 money
Relationship? market accounts for multiple entities, 5 brokerage accounts and 1 custody account.
If yes. please include relationship Total AUMs $224mn.
since date. approx # of accounts.
AUM. etc.)
Legal name of Account Prytanee, LLC
Holder(s)
Name of UBO(s) Jeffrey Epstein and Caroline Lang
(Please include UBOs who own
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25% and more: It there are multiple
layers. please include description
of ownership structure)
Description of Type of We are opening a deposit account for Prytanee LLC. The account will be used to
account being opened purchase art from up and coming artists.
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
S72532.06 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 (Y/N) No
If yes. include details
Any negative media Yes
and/or court cases?
Include ALL negative media &
court cases
If 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 do
for the relationship 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 Asset & Wealth Management
345 Park Avenue, 10154-0004 New York. NY. USA
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