EFTA01299302.pdf

Cynthia Rodriguez
From: Patrick Campion
Sent: Friday, October 14, 2016 5:02 PM
To: Cynthia Rodriguez
Cc: Armen Brash
Subject: RE: APPROVAL NEEDED: High Risk KYC Case 01651789 [II
Classification: For Internal use only
Approved. Just to be accurate, the client was presented to RRC and cleared.
Kind regards,
Patrick Campion
Patrick Campion
Managing Director I Head of Wealth Management America
Deutsche Bank Trust Company Americas
Wealth Management - Americas
345 Park Avenue. 10154-0004 New York, NY. USA
Tel
Mobile
Email
From: Cynthia Rodriguez
Sent: Friday, October 14, 2016 4:43 PM
To: Patrick Campion
Cc: Armen Brash
Subject: APPROVAL NEEDED: High Risk KYC Case 01651789
Hello,
I am requesting Exco Approval for the Butterfly Trust, an existing trust here at DB, under the Jeffrey Epstein relationship.
Mr. Epstein has replaced the beneficiaries to this trust, which is the reason for this KYC update.
RM Name Stewart Oldfield
Business Line US Onshore
GCIS # / KYC # 483290/ 01651789
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 a of accounts.
AUK etc)
Legal name of Account Butterfly Trust
Holder(s)
Name of UBO(s) Jeffrey Epstein
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(Please include USOs who own
25% end more: If Mere era multiple
layers, please include descnption
of ownership structure)
I
Description of Type of We are updating the beneficiaries to this existing trust account where Jeffrey
account being opened Epstein is the grantor.
with detailed purpose
of the accounts
(Please include SOW information/
Geographic location/
For Entity Accounts: Description of
the entity and background
lnformation 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 (YIN) No
If yes, include details
rATrnegative 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
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345 Park Avenue. 101540004 New York, NY, USA
Tel
F
Email
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