EFTA00166741.pdf

KYC Print Page 1 of 12 DB PWM GLOBAL KYC/NCA: PART A KYC Case # : 01082293 Status : 6. Approved One sheet must be established per relationshi • list all accounts included in the relationshi 1. Relationship Details Petationship Name: EPSTEIN, JEFFREY RELATIONSHIP: Booking Center: New York Relatiorah0 Manager: Paul Monis RI New PAN Relationship O Existing PWM Relationship Relationship to PWM: If existing, please indicate since when the relationship exists, provide reason for new profile and attach obi profile: LI Client Referral El RM Prospect ID Intermediary/PIM li Other Source (CIS, etc.) How Was the Client(s) Introduced, How long has the RH personally known the dent, Please provide details (e.g. amt of referral source, how many years RM personally ha known client, etc.): Jeffrey Epstein was a client of Paul's at JP Morg n. Paul and Jeffrey Epstein had a mutual friend/colleague who introduced them while Paul was at wmorgan. Over the course f a few meetings Paul was able to get Jeffrey to bring some of his funds over to Priorgan Does Deutsche Bank pay a retrocession or similar 0 Yes 12 No compensabon to a thid party for the Introduction of this relationship, pr Yee, describe List all existing and new MCOVIIIS InvoNed in this relationship Legal Entity Account(s) Account Name / Number Opening Date (intended/actual) I 2 Southern Financial, LI.0 8/19,0013 A Southern Financial, RIC 8/1912013 3 El Southern Teta Company, Inc. 8/1912013 4 El Southern That Company, Inc. 8/19/2013 Who is the primary contact person a the RN? (Note: This person needs to have signatory rights and/or Sweetish right for the accounts.): Jeffrey Epstein Preferred method of contact (nd•cate phone no., fax no., email addren etc. https://dbforcepb.my . sal esforce. com/servlet/servlet. Integration? lid=01N30000000D9Di8ce... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0002515 EFTA_000 15989 EFTA00166741 KYC Print Page 2 of 12 One sheet must be established for each account to be opened 2. Account Ownership Summary Account Name: Southern Financial, at Air I. hunter (if avaMiNe). kcounl Manager: Paul Morris What is the purpose of the account (e.g. portfolio management advisory account, custody services, long-term investment, payment/expense account)? Money Market. To hold funds for the company. Indicate O El w LA O (ran where the assets are expected to arrive? 08 Group: Same Booking Center (Indicate account muter): DB Group: Other Booldng Center (Indicate DB location and account details): Other Insfitutbn (Indicate name & location): )PMorgan, NYC Physical Deposits (specify cash, securltks, cheques....): What es the expected sire and frequency or regular inflows and outflows for the account (indicate estimated number and volume per month)?: Roughly 2 inflows & outflows per month rangkkg from $1000 to $10,000. What es the expected volume of assets and currency for the account approx. 90 days after opening? 1 50,E ICurrency I USD What is the expected volume of assets and currency for the account approx. one year after opening? 1 150,000 'Currency I USD Does/wi the client have Assets Under Management (AuM) within C6 under Eur. )M? • Yes El No Please list all parties related to the account. For each party: • Check if a source of wealth description it. required for the party. • Check the appropriate box to describe the relationship of the party to this account (> I can be selected). • f none of the check boxes apply, describe the party's relation to the account in the "Other column. • ?Mays &nate the rdationship between the parties in the last colAnn. • Please dril down to the ultimate/underlying Beneficial Owner(s). _egalbescription Entity,' Soiree al Wealth -Acquired Parties -elated to ins mcount AccountplC Molder OwnefTrust Settler of / Founder of Foundation Jitimate Bencficialor armer Signatoryskrniedrinancial FAA POA POA InterinediaryShareholdeditepresentative (FIN) Significant :>•2529) Non-PIC entity indicate ownership %) _egal Grantor/Sernorfounding Donor O Other "lease describe other roles and/or ndicate relationship between ?ernes) Sole shareholder of Southern Trust; l O 0 jeffreY E te ps in • O ILI O O O O O O 2 El El Southern arZlindll PI El IT O O O O O O n 3 2 0 Southern fnist Co want. Inc n❑"I O O D O DD ico O O Southern Trust is the sole member of Southern Financial and Jethey Epstein is the sole shareholder of Southern Trust; Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-0IN30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SIDNY-0002516 EFTA_000 15990 EFTA00166742 KYC Print Page 3 of 12 2. Account Ownership Summary Account Name: Southern Financial, La Acct. Number (d available): T Account Manager: Paul Morris What is the purpose of the account (e.g. portfolio minagemen advisory account, custody services, long-term investment, payment/expense account)'+ Checking account to hold funds for the company. Indicate from where the assets are expected to arrive' O 013 Group: Same Booking Center (indicate account camber): • DI3 Group: Other Boob% Center (indicate DB location and account details): @ Other Institutbn (Indicate name & location): )PMorgan, NYC O Physical Deposits (specify cash, soarers, cheques, ...): What Is the expected site and frequency of regular inflows and outflows for the account (indicate estimated number and volume per monthly: Roughly 10 inflows and 10 outflows per month ranging from $1,000 to $10,000. What is the expected volume of assets and currency for the account approx. 90 days alter opening? 150'000 I Currency I USD What is the expected volume of assets and currency for the account approx. one year after opening? 1 100,00D ICutrency I USD Does/wil the client have Assets Under Management (Ault) within 06 under Eur. 311? M Yes El No Please list all parties related to the account For each party: • Check If a source of wealth description is required for the party. • Check the appropriate box to describe the relationship of the party to this account (> I can be elected). • If none of the check boxes apply, describe the party's reaction to tbe account in the 'Other column. • Always describe t e relationship between the parties in the lad coltsnn. • Please drill down to the ultimate; undertying Beneficial Owner(s). .rigal)escretion Jntilyof Smote of Wealth -Nuked i sCCOUnt Notes related to his Account Holder PlC Owne(Trust Settler of / Founder of Foundation amide Beneficialor Owner SIgnatorebnitediFiriancial Rd POA PO* IntembellaryShareholdefeepresentative (PIM) Significant >=25%) Non-PIC entity ,Mdkate ownership Sb) _opt 'Grantee/Steno minding nor Other please describe other roles and/or ndirate relatonship Moroi Janie.) l • Fj Jeffrey EPsteln in 1--J O O O a O O O O Sole shareholder of Southern Trust; 2 la 9 Southern Financial La N • O • O O O O O O 3 Ea 0 Southern bus Company, Inc. is — mi O O O O O 1 CO O O Southern Trust Is the sole member of Southern and a rey Epstein Is the sole shareholder of Southern Trust; https://dbforcepb.my. sal esforce.com/serdet/servl et. Integration?lid=01N30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) 0B-SDNY-0002517 EFTA_0001599 1 EFTA00166743 KYC Print Page 4 of 12 2. Account Ownership Summary Account Name: Southern Trust Company, Inc. Acct. Number (laved/de) T Account Manager: Paul Morris What is the purpose of the account (e.g. portfolio management, advisory account, custody services, long-term investment, Parnell/Odense account)'+ Checking account To hold funds for company Indicate from where the assets are expected to arrive' O 06 Group: Same Booldng Center (indicate account limber): • 06 Group: Other Booldng Center (indicate DB location and account details): @ Other Instifutbn (Indicate name & location): )'Morgan, NYC O Physical Deposits (specify cash, diorites, cheques, ...): What is the expected size and frequency of regular inflows and outflows for the account (indicate estimated number and volume pe month)'': Roughly 10 inflows and 10 outflows per month ranging from $1,000 to $10,000 What 6 Use expected volume of assets and currency for the account approx. 90 days alter opening' 1 50,E I Currency I USD What is the expected volume of assets and currency for the account approx. one year after opening' 1 100,000 I Currency I USD Does/W6 the client have Assets Under Management (AM) within 06 under Eur. 311? • Yes 21No Please list all parties related to the account For each party: • Check If a source of wealth description is required for the party. • Check the appropriate box to describe the relationship of the party to this account (> 1 can be selected). • If none of the check boxes apply, describe the party's faction to the account in the 'Other' alum. • Always describe t e rdaticoship between the parties in the lad oakum. • Please del down to the ultimate/underlying Beneficial Owner(s). ..egal7escription lEntttyaf Source al Wealth required isccouM lodes elated to Ns Account Holder PlC Ownertrust Settler of / Founder of Foundation Jttimate Beneficialor Owner Signatoosimilietkiarttird HA POA POA IntemediaryShareholderttepresentative (FIM) Sigrilirant >=25%) lion-PIC entity ,Odicate wnershlp %) _egal Yiranter/Settbrkounding 2onor Other please describe other roles and/or nditate rciatonsho frutv.voi sanest I O El Jeffrey K idstein in i—J O O • A O O O O O Sole sh of areholder Southern Trust; 2 2 E Southern rant , :armful ,nc. Di il-' u u • O • O O O O https://dbforcepb.my. sal esforce.com/serdet/servl et. Integration?lid=01N30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) 0B-SDNY-0002518 EFTA_000 15992 EFTA00166744 KYC Print Page 5 of 12 2. Account Ownership Summary Account Name: Southern Trust Company, Inc. Acct. Number (rf availabl) Account Manager: Paul Morris What is the purpose of the account (e.g. portfolio manag ment, advisory account, custody se ekes, long-term investment, payment/expense account)> Money Market account. To hold funds for the company. Indicate from where the assets are expected to arrive' O 06 Group: Same Booking Center (indicate account combo): • 06 Group: Other Booking Center (Sdkate DB location and account details): Eil Other Institution (Indicate name & location): 3PMorgan, NYC O Physical Deposits (specify cash, securities, cheques, ...): What is the expected site and frequency of regular Inflows and outflows for the account Ondkate est mated number and volume pe month)'. Rouohly 2 inflows & outflows per month ranging from $1,000 to $10,000 What is the expected volume of assets and currency for the account approx. 90 days after opening' 1 5 '°C.3 I Currency II'S° What S the expected volume of assets and currency for the account approx. one year after opening' 1 150,000 I Currency I USD Does/wal the client have Assets Under Management (AuM) within DB under Eur. 3M? Likes RI No Please list all parties related to the account. For each party: • Check if a source of wealth description is required for the parry. • Check the appropriate box to describe the relationship of the party to thin account (> I can be selected). • If none of the check boxes apply, describe the party's reLotbn to the account b the Tithe- wham. • Mvays describe t e relationship between the parties in the tel colt.nn. • Please dn. down to the utimateunderlying Beneficial Owner(s) ,sgalDescriptkin ntttyof Source of Wealth -mitred ?rubes 'Mated to SS account Account Holder PlC OwnerTrust Settior of / -tender a Foundation Ultimate Beneficialor Owner SignatorykinSeerinancial Full PO4 ?OA /ntermediaryShareholderRepresentatree (FIN) Significant (i..75%) Non PIC only ',indicate ownership %) ..egal 'arantor/Settior"Sunding )onor Other please describe other roles orstror ndlcate relationship between Janie.) I O U Jeffrey Epstein in I--I O O O 121 O O O O n K Sok shareholder of Southern Trust: 2 74 31 Southern Trust Company, lbw- • • O O O • O O O O Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-0IN30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002519 EFTA_000 15993 EFTA00166745 KYC Print Page 6 of 12 One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa 3A. Individual Details (for all parties) individuals Name Jeffrey Epstein • Date of Birth: 1/20/1953 Country of Residence: USV1 Country of Cmzenship: USA Address of primary residence: Litte Saint James Saint lhomas 00802 US Virgin Islands Has client resided outside of his/her country of nationality for 5 years or more, No O yeg 12 Profession/Occupation: Self Empotyed Tax ID / SSN: Current Employer Southern Financial LLC Position/Title/Rank: President Address of employer: 6100 Red Hook Quarter 83 St. Thomas USW 00802 Does the person work as senior executive et a DB-recognized regulated enUty In the financial Sus or an entity hied on a DB-recognised exchange? (Not applicable for operating entities is yes E r.i r40 Is the iffilvidual a Pdltically Exposed Person (PEP)?(f Yes ckso-ibe) Dyes No To the best of your knowledge, Is the individual related to an employe* of the DB group(/' Family or FrierdsoNA dcsmbe ) O palm O Friendship 2 None To the best of your knowledge, is the inderiduzd party to a non-banking relationship with Deutsche Bank (e.g., external legal counsel, client referral source, supplier of goods or services), Or Yes,ckscate) O yes in Ng If applicable, indicate which bank officers have met the person: Indicate where and when the client meebnig(s) took place. Bank Officer Names) Bank Office: CUM Private DornIdle: Client Place of Business Cnher Location (specify): Date: Paul Morris O O 10 413i2013 0 0 • O O O O Wealth Details for this Individual are not filed h, because they are the same as for the following person: 38. Wealth Details (Only for parties requiring as Indicated In Section 2) source of wealth description Nature of the Individual's Business: Private nvestments Primary Country of source of wealth/source of Funds? Pnmary industry of source of Wealth/Source of Finds? Summarize Source of Wealth: WI Business O Other: Owner U Salary/Eamings 0 Investment U Inheritanceffins iurther Describe Source of Wealth /Detail the history of wealth for each of the sources: (e.g. fur trusts, how did senior accumuia e weakh? For Inheritance, how did family neurnithle wealthYlca business owners. how long in business, how many employes., level of profitability? Indicate type of bushes, countries of ma)pr activties, important business partners.) Epstein began his financial career in 19/6 as an options trader at Bear Stearns an became a partner ri 1980. In 1982, Epstein founded his own manual management firm, 1. Epstein & Co., managing the assets of clients with more than a NI n in net worth. In 1996, Epstein changed the name of hi firm to me Financial Trust Company and based a on the island cl St. Thomas in the US Virgin Islands. All of his clients wee anonymous except for the very wealthy businessman Leslie Wexner. His wealth has come from his days at Bear Stearns and his financial management firms I stimated Annual Incorne($): 10,000,000.00 Estimated amount of investable assets(y): $50 MN - 100 PIM Estimated Net Worth($): $100 MM - SOO MM Mount of asses planned to Irwest with PWM($): 10,000.00 other known Financial Institutions: Institution: 1ffilorgan Country: USA Est. Assets Under Mgt: 20,000,000.00 Institution: Country: Est. Assets Under Mgt: Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-0IN30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002520 EFTA_000 15994 EFTA00166746 KYC Print Page 7 of 12 Institution: Country: Est. Assets Under Mgt: Please indicate the farrity situation of the individual (ma tat status, other family members, etc.): ngle One sheet must be established for EACH LEGAL ENTITY in Section 2. Account Summary 3C. Legal Entity Details (For all Legal Entities) legal Entity Name: Southern financial ti C-- R Dust company O Estate purpose Cif Entity' /Commercial Z Prtvate Investment O Philanthropic/Charitable O K 'Assocotton MI O Foundatran O Partnership Type of Entity Other (specfy): Purpose of Entity Other (specify): Country of incorporation/registration: US Virgin Islands Date of Incorporation / registration: 2/25/2013 Vokker Status: Volcker Flag: Address (city, street. post code): 6100 Red Hook Quarter 83 St Thomas 00802 US Virgin Islands U.S. TIN;EIN: Provide a description of the entity's organuauonal structure, its ownetslip structure and Its Top Management. For trusts/foundations, include information about nwocabilly,settlor and benefkiaries,etc.: Southern Trust Company Inc b the sole member of Southern Financial 11.C. Jeffrey Epstein Is the sole shareholder ol Southern Trust Company Inc Please indicate how ownership of the legal entity is reflected: Southern Dust Company Inc Is the sole member of Southern Financial LLC. Jeffrey Epstein Is the sole shareholder of Southern Trust Company Inc O Special attention: Bearer Shares - Indicate where shares are custodied: Describe the chain from the died owner of the entity to the ultimate beneficial owner (dolt the sense pawns): Southern Trust Company Inc le the sole member of Southern Financial LLC. Jeffrey Epstein Is the sole shareholder of Southern Trust Company Inc TO the best of your knowledge, is the entity party toe non-banking relationship with Deutsche Bank (e.g. External legal counsel, client refers source, supplier of goods or services)): Yes O No 0 Describe Nature of Entity's Primary Business and Investment ActNIties Nature of the business: This business Is funded by Jeffrey Epstekt's wealth. This company was formed to hold Mr. Epstelds personal wealth and Invest In different ventures this company Invests in rest estate, equities, commodities, etc and gets is revenue from the gams it makes in these investments. It 6 a company formed to Invest the assets of Mr. Epstein Countries vdtere business Is transacted: US Virgin Islands Number of employees: 3 30. Wealth Profile (Only for parties requiring source of wealth description as indicated in Section 2) Primary Country of source of weakh/source of Funds' Primary industry of source of Wealth/Source d Funds' Provide Evidence of Corporate Assets (e.g. balance sheet or equivalent summary of assets/lablikies): The initial funding in February 2013 vies $1,000 from the sole shareholder of the sole managing member (Jeffrey Epstein) Estimated gross receipts pa.(3): 2,000,000.00 Estimated net profit p.a. ($) 1,500,000.00 Estimated investable assets (3): <$1 I4M Potential Amount to be Invested with PPM ($): 300,000 00 Other Known Financial Institutions: instRution: "Woman Country: USA Est. Assets Under Mgt: 1,000,00130) Institution: I Country: Est. Assets Under Mgt: Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-0IN30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002521 EFTA_000 15995 EFTA00166747 KYC Print Page 8 of 12 I Institution: One sheet must be established for EACH LEGAL ENTITY in Section 2. Account Summary 3C. Legal Entity Details (F-or all Legal Entities) Legal Entity Name: Southern Trust Company, Inc. Type of Entity: KO Foundabon/Assoclation O Trust W Company O Estate O Partnersibp Depose d Entite: Ed Private Investment O Philanthrople/Charkable El Commercial Type of Entity Other (specify): Purpose of Entity Other (specify): Country of incorporation/registration: US Virgin Islands Dote of Incorporation / registration: 11/16/2011 Volcker Status: Voklom IsHg: Address (city, street. post code): 6100 Red Hook Quarter B3 St Thomas 00602 US Virgin Islands U.S. TOWEIN: Pronde a description of the enteys organtrational structure, Its ownership structure and Its Top Manageniert. For trusts/foundations, Inekide information about revocability...odor and benefx lariesetc.: Please indicate how ownership of the legal entity n reflected: lefftey (Wert:sole managing member O Special attention: Bearer Shares - Indicate where shares ate custoded: Describe the chain from the Oen owner of the entity to the ultimate beneficial owner (if not the same persons}. Jeffrey Epstein is sole managing member To the best of your knowledge, Is the entity party to a nowbanking relationship with Deutsche Bank (e.g. external legal counsel, (bent referred source, suppler of goods or services?: Yes No :a • Describe Nature of Entity's Primary Business and Investment Activities Nature of the business: Consulting Services relying on FinarKlal and Blom edkal algorithm Southern Inn/ is a private consulting company that invests the assets of their clients and gets their revenue from the return of these investments. Southern Trust West; in different portfoIos catered to thor clients and makes their revenue based on the returns and the lees associated wilt managing their clients assets Counlnes where business is transacted: US Virgin Islands Number of employees: 4 Country: I UM AVAtt Under Llgt- I 3D. Wealth Profile (Only for parties rectum-mg source of wealth descnpbon as indicated in Section 2) Pitman, Country of source of wealth source of Funds') Primary industry of source of Wealth:Source of Funds, Provide Evidence of Corporate Assets (e.g. balance sheet or equivalent summary of assetslabilities): Consult and invest client funds and gain revenue based on fees and returns Estimated gross receipts p.a.($): 2,000,000 00 Estimated net pat p.a. ($3 L500,000 00 Estimated invadable assets (S) $2 MM • 5 MM Potential Amount to be invested with PV/TI (S): 300,000.00 Other Known Financial Institutions: Institution: iPMorgan Country: USA Est. Assets Under llgt: 2,000,000 CO Institution: Country: Est Assets Under Mgt: Institubon: (:ountry: Est. Assets Under Mgt: Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-0IN30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002522 EFTA_000 15996 EFTA00166748 KYC Print Page 9 of 12 DB PWM GLOBAL KYC/NCA: US/LatAm/Int'I PART B Relationship Name EPSTEIN, JEFFREY RELATIONSHIP Risk Rating Comment: Center RI NY • • moderate • Braking • Offshore •► Fr A High Risk iNY/Cffshore tisk (Compliance Signature) O NJ Employee O CO Managed PIC O DB es Trustee/Co-Trustee O Bearer Shares 4. Attachments A. Type of Photo ID Provided '14 Drivers Ucense gl Passport • National/State ID • Other B. Checklist of names (individuals and/or entitles) that were submitted for database searches Is • Yes • No attached C. Please indkate the results of the database searches perforrned RDC searches complete t.'d Yes O No negative result found 2 Yes O No PCR checks complete 7-4 Yes O No negative results found @Yes O No OFAC checks complete .4 Yes • No negative results found • Yes @ No ElIS searches complete (.eds/Neds, Factiva, Reuters, Dow Jones, Des) @Yes O No negative result found ['Yes @No Denial Orders checks complete 74 yes O No negative results found • Yes No Martindale-Hubbell searched (Lawyers/Law Rum or/y) • Yes 74 No negative results found • Yes O No D. Please summarize any negative results from the database searches indkated above: JEFFREY EPSTEIN: RDC Alert • I -- Cleared & APPROVED by Chip Packard, Alt Compliance, and Pat Harris PCR Alert a 1/2 -- Not our client All Cases Closed SOUTHERN FINANCIAL LLC: No negative media No court cases SOUTHERN TRUST INC: No negative media Court Case -- Not our diem. FINANCIAL INFOMATIa INC: No negative media No court cases J. Epstein & Co. All Negative Media is our client. He has been cleared of pesky a reputational risk as shown by the AMR Clearance attached Court Cases have been dosed FINANCIAL TRUST & CO RDC/PCR alert is associated with Southern financial, the company it merged into. This alert has been cleared by Compliance and is attached Court Cases are closed E. To the best of your lawidedge, has the client ever been convicted of a criminal offense? @Yes • No F To the best of your knowledge, has the customs ever been Involved In any past litigation against Deutsche Bank AG or any of its subsidiaries or is the customer threatening litigation against O Yes I21No Deutsche Bank AG or any of Its subsidiaries? (hr Yes, porde debit below and rotted Quality Mgt 4LatelogThet or Regulatory Control Group and notify Comps:once immediateM G. Does the client or related party have any Oriental or other association / interactions within countries • yes 74 No or regimes sanctioned by the Office of Foreign Assets Control ((PAC)? ii. Does the client or related party have any financial or other association/ Interactions within high risk • yes n No countries? I. Corporate Documentation Attached (Legal Entities Only) @Yes • No O Not Applicable https://dbforcepb.my.salesforce.com/servlet/servIet.Integration?lid=01N30000000D9Di&e 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002523 EFTA_000 15997 EFTA00166749 KYC Print Page 10 of 12 I. Undisclosed Principal Form Complete (Intermediarks Only) One Ono /21NotAppicable K. If lerisiNexis Search Results, Corporate Documents or Other Supporting Documentation Is not in English, please provide on English summit, &the nature/contents of the non.English Documentation: L. Special Risk Factors Does the account have Nexus to Special Risk Countries? ayes la No Is the account structure unusual'', complex? ayes ®No Is there any indication the client set up a non operating correany expressly for the purpose of transferring shares to third parties? .1. ... re Yes C_INo Is there any indication this could be a prohibited business relationship' • yes ®No Are the bearer shares identified subject to acceptable controls' O yes @No Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-0IN30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002524 EFTA_000 15998 EFTA00166750 KYC Print Page 11 of 12 l eo records to display. H. Case Comenents ONSHORE APPROVALS Client Facing &Sal (CFP): Paul Moms ,.Signature) 7aul Morris 7/17/2013 0Mce Director/Business Mead: Brian M. Beggar Signature) Snail H. Biggar 7/18/2013 Regional Offke Director: Signature) Art Business Risk: Armen &ash (Signature) Armen Brash 8/20/2013 AK CompBanat: Janice Franklin (Saanature) Janice Franklin 8/21/2013 UTAH /INTERNATIONAL APPROVALS Client Facing Pr&essional (CFP): (Signature) Account Manager: (Signature) eaobal Market Team Head (2.1111)1Sub-Market Team lit-ad 5/1T11)' (Signature) All. Business Risk: (Signature) Alit Compliance (Signature) PRIVATE WEALTH MANAGEMENT POLICY STATEMENT: Deutsche Rank Private Wealth Management (PWM) worldwide is committed to professionally serve the interests of its clients. To do so. Client Facing Professionals)(!) (CFP 's) should establish and maintain business relationships only with persons who satisfy our high standards of suitabili0i, background and character. Due diligence obtained on the client must be appropriately documented by the CFP. It is the responsibility ofCPP's to demonstrate that they know their client both at the inception of a relationship and on an ongoing basis. DECLARATION FOR ALL SIGNERS OF THIS FORM: To the best ofmy knowledge and belief the above information is correct and up to date. I confirm that ! have no suspicions relating to the money laundering or unethical activities on the part of the clients) and that! have followed all the procedures relating to account opening as described in the PWM Americas Procedures and the PWM Global KYC Policy (1) Client Facing Professionals (GP's) include: Relationship Managers. Wealth Prodiet ()mi. el., Brokers. Client Managers. etc. Deutsche Bank Americas New York Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-OIN30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002525 EFTA_000 15999 EFTA00166751 KYC Print Page 12 of 12 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... 7/18/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002526 EFTA_000 16000 EFTA00166752