https://www.justice.gov/epstein/files/DataSet%2010/EFTA01362433.pdf
KYC Print Page 33 of 34
M. Case Comments
Created By Date Comments
Client was contacted via phone on 6/28/2017 to confirm there are no material changes to
Cynthia Rodriguez 7/6/117 2:41 AM
his single member LLCs at DB
This KYC serves as a high risk update for the below listed clients (together
"accountholders") —
1. Zarro Management, LLC
2. LSJE, LLC
3. Mort, Inc
4. Jeepers Inc
S. Hyperion Air, LLC
6. Plan D LLC
7. JEGE LLC
8. JEGE Inc
Below are the reasons why we are comfortable with approving this KYC:
• Information and supporting documents required by our AML Policy were provided and
Kshiti) Golani 8/19/117 1:06 AM
reviewed; and as a result, we have an understanding of the structure of the accountholders,
their purpose, the purpose of the accounts and expected transaction activity.
• There are a few nsk factors associated with the accountholders —
SOW: The UBO (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which
manages client's assets. SOW verification was obtained.
Negative Media & PEP: There is some negative media against Mr Epstein and he is also
maintains a close relationship with Bill Clinton and Prince Andrew. Please see risk calculator
for more information. Appropriate approval was obtained.
• Our review did not identify any red flags and thus there was no need to escalate this case
further.
• We performed due diligence searches on all parties and did not find the names searched to
be on any sanctions lists
ONSHORE APPROVALS
Client Facing Professional stewart oldfield (Signature) 6/29/2017
(CFP): stewart oldfield
Office Director/Business Head: Andrew F Gallivan (Signature) 7/5/2017
Andrew F Gallivan
Regional Office Director: (Signature)
AML Business Risk:
(Signature)
AML Compliance:
(Signature)
Kshiti) Golani Kshitg Golani 8/18/2017
Yoonsun Chung Yoonsun Chung 8/18/2017
LATAM/INTERNATIONAL APPROVALS
Client Facing Professional (Signature)
(CFP):
Account Manager: (Signature)
Global Market Team Head (Signature)
(GMTH)/Sub-Market Team Head
(SMTH):
AML Business Risk:
(Signature)
https://dbforcepb.my.salesforce.com/servlet/senflet.Integration?lid=01N30000000D9Di... 8/2/2018
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0051839
CONFIDENTIAL SDNY_GM_00198023
EFTA01362433
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Add API Key in SettingsKYC Print Page 33 of 34
M. Case Comments
Created By Date Comments
Client was contacted via phone on 6/28/2017 to confirm there are no material changes to
Cynthia Rodriguez 7/6/117 2:41 AM
his single member LLCs at DB
This KYC serves as a high risk update for the below listed clients (together
"accountholders") —
1. Zarro Management, LLC
2. LSJE, LLC
3. Mort, Inc
4. Jeepers Inc
S. Hyperion Air, LLC
6. Plan D LLC
7. JEGE LLC
8. JEGE Inc
Below are the reasons why we are comfortable with approving this KYC:
• Information and supporting documents required by our AML Policy were provided and
Kshiti) Golani 8/19/117 1:06 AM
reviewed; and as a result, we have an understanding of the structure of the accountholders,
their purpose, the purpose of the accounts and expected transaction activity.
• There are a few nsk factors associated with the accountholders —
SOW: The UBO (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which
manages client's assets. SOW verification was obtained.
Negative Media & PEP: There is some negative media against Mr Epstein and he is also
maintains a close relationship with Bill Clinton and Prince Andrew. Please see risk calculator
for more information. Appropriate approval was obtained.
• Our review did not identify any red flags and thus there was no need to escalate this case
further.
• We performed due diligence searches on all parties and did not find the names searched to
be on any sanctions lists
ONSHORE APPROVALS
Client Facing Professional stewart oldfield (Signature) 6/29/2017
(CFP): stewart oldfield
Office Director/Business Head: Andrew F Gallivan (Signature) 7/5/2017
Andrew F Gallivan
Regional Office Director: (Signature)
AML Business Risk:
(Signature)
AML Compliance:
(Signature)
Kshiti) Golani Kshitg Golani 8/18/2017
Yoonsun Chung Yoonsun Chung 8/18/2017
LATAM/INTERNATIONAL APPROVALS
Client Facing Professional (Signature)
(CFP):
Account Manager: (Signature)
Global Market Team Head (Signature)
(GMTH)/Sub-Market Team Head
(SMTH):
AML Business Risk:
(Signature)
https://dbforcepb.my.salesforce.com/servlet/senflet.Integration?lid=01N30000000D9Di... 8/2/2018
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0051839
CONFIDENTIAL SDNY_GM_00198023
EFTA01362433