EFTA01299337.pdf

From: Gwen MB
To: PWMUS AMLRYC
Cc: Gwen Hill
Subject: CLEARED: PEP Escalation_Jeffrey E. Epstein
Date: Monday, October 22, 2018 8:53:18 AM
Attachments: imaoe003,202
From: Janice Franklin
Sent: Friday, October 19, 2018 5:16 PM
To: Gwen Hill
Subject: RE: PEP Escalation_Jeffrey E. Epstein
Hi Gwen:
I agree with your assessment that Mr. Epstein should be treated as a RCA. Hence, all clients where
he is UBO or has a significant controlling role should be automatically risk rated "High"
Regards,
Janice P. Franklin
Janice Franklin, CAMS, CFSA, CFIRS
Vice President I AML Compliance Officer
Deutsche Bank Americas
Regulation. Compliance 8 Anti-Financial Crime
60 Wall Street, 10005-2836 New York, NY, USA
From: Gwen Hill
Sent: Friday, October 19, 2018 2:30 PM
To: Janice Franklin <janice.franklinPdb.com>
Subject: RE: PEP Escalation_Jeffrey E. Epstein
Hi Janice,
The purpose of this email is to address the PEP status of Jeffery E. Epstein, an existing Wealth
Management client through the Southern Financial Relationship. Although the PEP status was
factored into the prior risk calculator, the client was never formally escalated as a PEP.
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It has been reported in the media that Mr. Epstein has maintained a close relationship with Prince
Andrew, Duke of York and member of the British Royal Family and former US President, Bill Clinton.
Several media sources have reported Mr. Clinton and Prince Andrew have used Mr. Epstein's private
passenger jet "Lolita Express" on numerous occasions.
The relationship is currently "High" Risk. Although Mr. Epstein was treated as an honorary PEP in the
past, he was never formally escalated as a PEP. BLAFC-WM reached out to the business and they
agreed he should remain a PEP. Please let us know if you agree that Mr. Epstein should be treated
as a Relative or Close Associate (RCA) of a PEP due to his connections to Prince Andrew and Bill
Clinton.
Kind regards,
Gwent,H al.
Gwen Hill
AVP I AML Compliance Officer
DB USA Core Corporation
Regulation. Compliance and Anti-Financial Crime
Anti-Financial Crime
loor, 32256 Jacksonville, USA
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