EFTA00167035.pdf
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Extracted Text (OCR)
KYC Print
Page 1 of 14
DB PWM GLOBAL KYC/NCA: PART A VA
KYC Case z :01651769
Status : 6. Approved
One sheet must be established per relationship - list all accounts included in the relationshi
1. Relationship Details
Relationship Name:
EPSTEIN, JEF₹REY RELATIONSHIP:00000483290
Booking Center:
New York
Relationship Manager:
Stewart adtleld
•
New PWM Relationship
O
besting PWM Relationship
Relationship to MN:
If existing, please indicate since when the relationship exists, provide reason for new profit and attach old profile: Update of
I(YC 801133113. Beneficiaries have changed
0
Client Referral
•
RM Prospect
O Intermediary/FIM
LI Other Source (CI8, etc.)
How Was the Clients)
Introduced' How long has the
RM personally known the
dent'
Please provide details (e.g. name of referral source, ow many years RR personally has known client, etc.): Jeffrey Epstein
(President of Gratitude Amerka) is a current client of the bank and reached out to Stewart Cldfield to update the beneficiaries
to his Butterfly Trust
Does Deutsche Bank pay a
retrocesskm or smiler
•
Yes
I 0
No
compensation to a third party
for the ntroduOon of this
relationship'
(ff Ya, describe)
List all exestmg and new accounts involved in this relationship
Legal Entty
Account(s)
Account Name / Number
Opening Date (intended/actual)
1
0
Butterfly Trust -- Checkeig
10/9/2013
2
Ei
Butterfly Trutt -- Money Market
10/9/2013
Who Is the primary contact
person for the RM' (Note:
This person needs to have
signatory rights and/or
information right for the
accounts.):
Many Beler
Preferred method of contact
(indicate phone no., fax no.,
e-mail address, etc):
-
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One sheet must be established for each account to be opened
2. Account Ownership Summary
Account Name:
Butterfly Trust -- Checking
Acct. Number Of avai.tAW
Account Manager:
Paul Morris
What is the purpose of the account (e.g. portfolio management advisory account, custody services, long-term investment, payment/expense account), This is
a checking account to hold funds for the trust.
Indicate from where the assets are expected to arrive/
•
DB Group: Same Booking Center (indicate account number):
O DB Group: Other Booking Center (Indicate 08 location and account details):
Eil Other Institution (Indicate name & location): Whlorgan. New York, NY
(1 Physkai Deposits (specify cash, securities, cheques, ••.):
What is the expected site and frequency of regular Inflows and outflows for the account (Indicate estimated number and volume per month)/: Roughly 540
Inflows and outflows per month ranging from $1,000 to $20,000
What is the expected volume of assets and currency for the account approx. 90 days after
opening/
I
I Currency
I USD
What is the expected volume of assets and currency for the account approx. one year after
opening/
15,000,000.00
ICurrency
I USD
Does/will the client have Assets Under Management (MN) within 08 under Eur.
?
II Yes n 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 (> 1 can be selected).
• If none of the check boxes apply, describe the party's relation to the account in the 'Other' column.
• Always describe the relationship between the parties in the last olunin.
• Please drill down to the ultimate/underlying Beneficial Owner(s)
.eganescripUon
Entity of Source
of Wealth
required
Parties
related
to this
account
AccoundPIC
Holder OwnerTrust
Settler of
/
Founder of
toundabon
Admate
Benefk rat
Owner
'Senator
Df Full
?0A
inytednancial
A
Mennedmiry
(FIN)
Significant
Shareholder
(>=25%)
slon-PIC
entity
tracheate
ownership
%)
Legal
Representative
GrantoriSettlorboundmgOther
Donor
(please
describe
other roles
and/or
indicate
relationship
between
dies
I
O
El
jeffrn O
O
K
o
Epstein
•
O
O O
O
O
O
Grantee;
2
0
0
Marry
Belles
0
D
ei
0
115
Ill
0
0
•
0
lhistec
3
•
•
Ede
Kellerhals O
O
•
O
2
O O
O
O
•
Trustee::
4
5
12]
Buttetilna
Trust
O
O
•
O
O
•
O
.
O
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2. Account Ownership Summary
Account Name:
Butterfly Trust •• Money Market
Acct. Number (//avtlahlet.
Account Manager:
Paul Morris
What is the purpose of the account (e.g. portfolio management advisory account custody services, long-term invesbnent payment/expense account)' Money
Market accomt. To hold cash for the trust to earn interest
Indicate from where the assets are expected to arrive'
C3 DB Group: Same Booking Center (indicate account number):
O DB Group: Other Booking Center (indkate DB location and account debts):
2 Other Institution (Indicate name A location): IPtiorgan. New York, NY
O Physical Deposits (specify cash, securities, cheques, ..j:
What is the expected size and frequency of regular inflows and outflows for the account (indicaW estimated number and volume per month)': Roughly 1-2
nnows and 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
openings
I
I Currency
I USD
What is the expected volume of assets and currency (or the account approx. one year after
opening'
1 1,000,000.00
I Currency
I uSD
Does/will the client have Asset Under Management (AuM) within DB under Eur.
?
i Yes 2 No
Please list an parties Sated to tM 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 ch ck boxes pply, describe the party's relation to the account In the 'Other' column.
• Always describe the relationship between the parties in the last olumn.
• Flease drill down to the ultimate/underlying Beneficial owner(s)
.egal
Entity
Description
of Source
I Wealth
required
Parties
related
to this
account
AccounWiC
Holder OwnerTrust/
Setflor of
Founder of
foundation
JltirnaW
Beneficial
Dreier
tisatorysimitedlignancial
or Full
>OA
'OA
InterinediaryShareholder
(FIN)
Significant
(>=25%)
Non-PIC
entity
(Indicate
ownership
)6)
Legal
Representative
Grantor/Settle-oundingOther
Donor
(please
describe
other roles
and/or
indicate
relationship
between
parties)
Grantor;
1
O
2
Epstein
O
O
9
O
O
O
O
O
O
O
2
5
Butterfly
Trust
Ea
O O
•
O
O O
O
O
O
3
•
•
"Beller
•
O
O
•
O
O
•
O
•
O
Tr ustee: ;
4
LI O
Erika
K
Kellerhak ri
I-I
•
•
O
2
El O
•
O
O
Trustee:;
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must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa
3A. Individual Details (for all parties)
Individual's Name:
Jeffrey Epstein - 00000483289
Date of Birth.
1/20/1953
Country of Residence:
USVI
Country of Obzenship:
USA
Address of primary residence: Me Saint James Saint Thomas 00802
Has client resided outside of
Ns/her country of nationality
for 5 years or more
El yes giNo
ProfessionfOccupabon:
Self Employed
Tax ID / SSN:
Current Employer:
Southern Financial LLC
Position/Title/Rank:
President
Address of employer:
6100 Red Hook Quarter B3 St. Thanes 00802
Does the person work as senior executive of a DB-recognized regulated entity in the financial
industry' or an entity listed on Derecognrsed exchange' (Not applicable for operating entitles
r-7
L...I Yes Z No
Is the individual a Polibcally Exposed Person (PEP)'(// Yes, ckscnte)
O Yes
No
E4g
To the best of your knovAedge,
FM*
Friendshs describe)
Is Me individual related to an employee of the D8 group'(,
I:Family
Ornery:HMIs
2 None
or
To the best of your knowiedge, is the individual party to a non-banking relationship with
Deutsche Bank (e.g., external legal counsel, client referral source, suppler of goods or
services)'(/ Yes,thrscnbe)
•
Yes
Ei No
If applicable, indicate which bank officers have met the
person:
Indicate where and when the client meeting(s) took place:
Bank Officer Name(s)
Bank Office:
Client Private
Domicile:
Client Place of
Business:
Other Location (seedy):
Date:
Paul Morris
O
0
9/13/2013
•
O
o
O
ID
El
•
0 Wealth Details for this individual are not filled in, because they are the same as for the following person:
38. Wealth Details (Only for parties requiring source of wealth description as indicated in Section 2)
Nature of the Inclivcduars Business:
Private hnwb,ients
Primary Country of source of wealth/source of Funds'
Primary industry of source of Wealth/Source of Funds'
Summarize Source of Wealth:
g Business owner 0Salary/Earnings RInvestrnent 0 Inheritance/Gifts 0 Other:
Further Describe Source of WeaRh /Detail the history of swath or each of the sources: (e.g. For trusts, how did settlor accumulate wealth' For inheritance,
how did family accumulate wealthiFor business owners, how long in bushiest, how many employees, level of profitability' Indicate type of business, countries
of mayor activities, rnportant business partners.) Epstein begs his financial career in 1976 as an options trader at Bear Stearns and became a panned n
1980. In 1982, Epstein founded his own finance] management firm,./. Epstein & Co., managing the assets of clients with more than a bibon In net worth. In
1996, Epstein changed the name of his firm to The Financial Trust Company and based it on the island of St. Thomas In the US Virgin Islands. Al of his clients
were anonymous except for the very wealthy businessman Leslie Wexner. its wealth has come from his days at Bear Steams and his financial management
firms
Estimated Annual Income(i):
10,000,000.00
Estimated amount of investable assels($):
$50 MM - 100 MM
Estimated Net Worth(i):
$100 MM • 500 MM
ArnouM of assets planned to invest with PWM($):
5,000,000.00
Other Known Financial Institutions:
InsIltution:
JPil
Country:
USA
Est Assets Under Mgt:
120,080,00000
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KYC Print
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institution:
Deutsche Bank
Countyy.
USA
Est Assets Under Mgt:
70,000,000.00
Institution:
Counby.
at Asseb Under Mgt:
Please indicate the Varney situabon of the individual (mantel status, ether family members, etc.):
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EFTA_000 16287
EFTA00167039
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One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa
3A. Individual Details (for all parties)
IndMduars Name:
Harry Beller -
Date of Birth
Country of Residence:
USA
Country d Ctzenship:
USA
Address of primary residence:
Has client resided outside of
his/her country of nationality
for S years or more
O yes ®No
Profession/Occupabon:
Accountant
Tax ID / SSN:
Current Employer
HBRK Associates, Inc
Position/Title/Rank:
Address of employer:
575 Lexington Avenue, 4th Floor Monsey NY United States 10022
Does the person work as senior executive of a DB-recognized regulated entity In the financial
ridustry, or an entity listed on
DB-recognised exchange' (Not applicable for operating entitles
r-7
L..l Yes Z No
Is the individual a PoliticaPy Exposed Person (PEP)>(d Yes, descnbe)
Chet
E4g No
To the best of your knovAedge,
Family
Friendylma,
Is the Individual related to an employee of the DB group'(d
0 Family
Chien:Wile
2 None
or
*scribe)
To the best of your knowSedge, is the individual party to a non-banking relationship with
Deutsche Bank (e.g., external legal counsel, client referral source, suppler of goods or
services)'(/ Yes,thrserbe)
No
• Yes
0
If applicable, indicate which bank officers have met the
person:
Indicate where and when the client meeting(s) took place:
Bank Officer Name(s)
Bank Office:
Chent Private
Domicile:
Client Place of
Business:
Other Location (seedy):
Date:
O
O
•
O
ED
•
ID
El
a
0 Wealth Details for this individual are not filled in, because they are the same as for the following person:
38. Wealth Details (Only for parties requiring source of wealth description as indicated in Section 2)
Nature of the Indivcduars Business:
Primary Country of source of wealth/source of Funds'
Primary industry of source of Wealth/Source of Funds'
Summarize Source of Wealth:
DElusiness owner 0 Salary/Earnings 0 Investment 0 Inheritance/Gifts 0 Other:
Further Describe Source d Wealth /Detail the history of wealth or each of the sources: (e.g. For trusts, how did senior accumulate wealth' For inheritance,
how did family accumulate wealth'For business owners, how long In bushiest, how many employees, level of profitability' Indicate type of business, countries
of miler activities, important business partners.)
Estimated /must Income($):
Estimated amount of investable assets($):
Estimated Net Worth($):
Amount of assets planned to invest with PWTI($):
Other Known Fnancral Institutions:
Institution:
Country:
Est Assets Under Mgt:
Institution:
Country:
Est Assets Under Mgt
Institution:
Country:
Est Assets Under Mgt:
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Please indicate the family sltuabas of the individual (manta, status, other family members, etc.):
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EFTA00167041
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One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa
3A. Individual Details (for all parties)
Individual's Name:
Enka Kellanais -
Date of Birth
Country of Residence:
USA
Country d Catienship:
USA
Address of primary residence:
Has client resided outside of
Ns/her country of nationality
far S years a more
El yes giNo
Profession/Occupabon:
Attorney
Tax ID / SSN:
Current Employer
Kelatals Ferguson Kroblin PLLC
Position/Me/Rank:
Address of employer:
9100 Pat of Sale Mall, Ste IS St Thomas 00802
Does the person work as senior executive of a DB-recognized regulated entity In the financial
ridustry, or an entity listed on
DB-recognised exchange' (Not applicable for operating entitles
r--,
LI Yes Z No
Is the individual a Politically Exposed Person (PEP)>(dYes, cksente)
O Yes
E4g No
To the best of your knovAedge,
FM*
Friendshs describe)
is Me individual related to an employee of the D8 group'(d
0 Family
0 Frierxtrhip
2 Nine
or
To the best of your knowiedge, is the individual party to a non-banking relationship with
Deutsche Bank (e.g., external legal counsel, client referral source, suppler of goods or
services)'(/ Yes,decarbe)
No
• Yes
0
If applicable, indicate itch bank officers have met the
person:
Indicate where and when the client meeting(s) took place:
Bank Officer Name(s)
Bank Office:
Client Private
Domicile:
Client Placed
Business:
Other Location (specify):
Date:
O
O
•
O
o
•
ID
El
a
0 Wealth Details for this individual are not filled in, because they are the same as for the following person:
38. Wealth Details (Only for parties requiring source of wealth description as indicated in Section 2)
Nature of the Indiv`dualls Business:
Primary Country of source of wealth/source of Funds'
Primary industry of source of Wealth/Source of Funds'
Summarize Source of Wealth:
0 Business owner 0 salary/Earnings 0 Investment 0 Inheritance/Gifts 0 Other
Further Describe Source d Wealth /Detail the history of wealth or each of the sources: (e.g. For trusts, how did senior accumulate wealth' For inheritance,
how did family accumulate wealth'For business owners, how long in business, how many employees, level of profitability' Indicate type of business, countries
of major activities, important business partners.)
Estimated /must Income($):
Estimated amount of investable assets($):
Estimated Net Worth($):
Amount of assets planned to invest with PWTI($):
Other Known Enamel Institutions:
Institution:
Country:
Est Assets Under Mgt:
Institution:
Country:
Est Assets Under Mgt
Institution,
Country:
Est Assets Under Mgt:
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Please indicate the fart* situatiai of the individual (marital status, other family members, etc.):
I
One sheet must be established for EACH LEGAL ENTITY In Section 2. Account Simms
3C. Legal Entity Details (For al Legal Entitles)
Legal Entity Name:
Butterfly Trust - 00000486926
Type of Entity:
Purpose of En bty:
Fiiel Private Investment El
PhilanthropiciChantable [..)
Commercial
E
ia
Foundabco,Assoc tion R Trust
N
Company Ei Estate
O Partnership
Type of Entity Other (specify):
Purpose
Other (s
of Entity
(specify)-.
Country of
incorporabon/regiSbabon:
USA
Date of
regista
incorporatkin i
boo:
12)27)2006
Yokker Status:
Determination Reputed
Vokker Rag:
No
Address (city, stet post
coder
6100 Red Hook Quarter B3 St, Thomas 00802 United States
US. TIN/EIN:
Provide a description of the enblYs
revocabilty,settior and benefici
This is an inevocable trust set
r
lifer
and Erika Kenitrais.
Duren lndyke
Karyna Shullak
RI:hard Kahn
organizational structure, ls ownership structure and its Top Management For trustsfloundabons, Include information about
ries,etc.:
p by Jeffrey Epstein as the grantor. The the beneficiaries for the trust are berig updated by the current trustees. The trustees
The beneficiaries are:
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EFTA00167043
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I tached are the original trust agreement and the addition/deletion of beneficiary Instrument to support this change. According to the algMal trust agreement,
re trustees have the right during the lifetime of the Grantor to delete or add beneficianes under fund. 3 of the agreement.
Please indicate how ownership of the legal entity Is reflected: trust agreement
O
Special attention: Bearer Shares - Indicate where shares are custodial:
Describe the chain from the direct owner of the entity to the ultimate beneficial owner Of not the same persons) This is an irrevocable trust set up by Jeffrey
Epstein as the grantor. The the beneficiaries for the bust are being updated by the current trustees. The trustees are Harry Beier and Enka Keikrhah.
To the test of your knowledge, is the entity party to a non-banking relationship with Deutsche
Bank (e.g. external legal counsel, client referral source, supplier of goods or servicesr
'Yes .
NO
Describe Nature of Entity's Primary Business and Investment Activities
Nature of the busoess:
Trust account
Countries where business is transacted.
USA, USVI
Number of employees:
N/A
3D. Wealth Profile (Only for parties requirog source of wealth description as indicated in Section 2)
Primary Country of source of wealthisource of Funds,
Primary industry of source of Wealth/Source of Funds,
Provide Evdence of Corporate Assets (e g. balance sheet or equivalent summary of assets,nabloes):
Trust account with Jeffrey Epstein as Grantor Initial $100 green to the account to fund. The funds for the trust account come from mvestments made by Jeffrey
Epstein. His wealth profile is fined out. The trust is for the benefit of the 6 named individuals
Estimated gross receipts p a ($):
4,500,000 00
Estimated net profit pa. (5):
4,500,000.00
Estimated investable assets (5):
S5 Mil - 10 MM
Potential Amount to be invested with PiVni (S):
4,500,000 00
Other Known Financial Institutions:
Institution:
3PHorgan
Country:
USA
Est. Assetr Under 14gt:
4,500,000.00
Institution:
Country.
Est. Assets Under Mgt
Institution:
Country:
Est. Assets Under Mgt:
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EFTA00167044
KYC Print
Page 11 of 14
DB PWM GLOBAL KYC/NCA: US/LatAm/Int'l PART B
Relationship Name
EPSTEIN, JEFFREY RELATIONSHIP
Risk Rating Comments:
Booking Center
El NY
O
/Offshore
O Moderate
isk
2 High Risk
Yoonsun Chung
• Offshore
(Compliance Signature)
El DB Employee
O DB Managed PIC
O DB Is Trustee/Co-Trustee
O Bearer Shares
4. Attachments
A. Type of Photo ID Provided
Driven License FA Passport ONationagState ID a Other
B. Checklist of names (ndividuals and/or enbties) that were submitted for database searches is
attached
Ores El No
C. Please indicate the results of the database searches performed
RDC searches complete
e yes 0 No
negative results found
0 'it 0 No
PCR checks complete
Ores O No
negative results found
0 Yes O No
OFAC checks complete
®Yea ONO
negative results found
Olt
O No
85 searches complete (Leds/Nexls, Facbva, Reuters, Dow Jones, DEU3)
0 yes O No
negative results found
5 Yes O No
Denial Orders checks complete
Wires O No
negative results found
• `Magi No
Manandale•Hubbel searched (Largos/Law Mims only)
Ores 5 No
negative results found
Ora 0 No
D.
Please summer oe any negative results from the database searches indicated above:
BUTTERRY TRUST:
Negative Media: All negative media pertain to a company called the Butterfly Trust in Europe. This Is not our client Our client is an actual trust Created by
a Grantor and not a company.
No court cases
JEFFREY EPSTEIN:
Previously approved KYC a:01082293 & 01121718
MI negative media pertains to court cases which have been previously approved in the above mentioned KYCs.
Court Cases have been closed
RDC alerts ffor Rkhard Kahn cone is but they were all false positives as the age and locaban of the alerts did not match the age and address on file.
HARRY BELLER:
No negative media
Court case lists him as a defendant for bong chief of medical staff for Jackson Memorial Hospital. The court concluded that the plaintiff had no cogntrable
clam that his civil rights has been violated, but refused to dismiss his complaint as to his anbtrust claim Defendants' motion was thus granted in part and
denied in part. The defendants listed in this case have not cornmiNed any illegal acts of conduct in any way. The case was settled on 6/30/1987.
ERIKA KELLERRALS:
No negative media
Erika Is an attorney and listed as legal counsel for several court case. Cart case to appeal from a decision of the bankruptcy court. Appellee trustee moved
to dismiss the appeal for failure to prosecute under Fed R. of the six Poulls factors, five weighed in favor of disrnssal and It was granted. Another court case
for dissolving of marriage and property settlement. The case was concluded.
E. To the best of your knowledge, has the client ever been convicted of a criminal offense'
5 yes • No
F
To the best of your knowledge, has the customer ever been Involved In any past litigation against
Deutsche Bank AG or any of its subsidiaries or Is the customer threatening Negation against
Deutsche Bank AG or any of its subsidanes" al Yes, provide details below and contact QUellityAlgt. O Yes 0 No
aatAm/Pe0 or the &Winery Control Group and notes' Compliance immethateA9
G. Does the client or related party have any financial or other association / interactions within
countries or regimes sanctioned by the Office of Foreign Assets Control (OFACP
O Yes
No
H. Does the client or related party have any financial or other association/ interactions within high risk
ms
countries'
Yes ou No
I
Corporate Documentation Attached (Legal Entities Cady)
5 Yes O No O Not Amicable
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EFTA00167045
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Page 12 of 14
1.
Undisclosed Principal Form Complete (Intermediaries Only)
O Yes O No 2INot Appkable
K. If Lexisfilexis Search Results, Corporate Documenh or Other Supporting Documentation is not in English, please provide an English summary of the
natureicontents of the nen-Engish Documentation:
L. Special Risk Factors
Does the account have Nexus to Special Risk Countries'
Oyes c No
Is the account structure unusualy complex?
Oyes E No
Is there any indkation the client set ups non operating company expressly
for the purpose of transferring shares to third parties?
ri
LJ Yes W No
Is there any Indkaton thls could be a prohibited business relationship'
O Yes 42 No
Are the bearer shares kknbfled subyect to acceptable conbols?
°Yes E No
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DB-SDNY-0002820
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KYC Print
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M. Casa Comments
Created By
Date
Comments
Cynthia Rodriguez
2/2/117 9:SS AM
Email confirmation from Jason Shames is attached.
Cynthia Rodriguez
12/30/116 11:29 API
During the 1fetime of the granter, the trustees have the right to add/delete beneficiaries under Artick Third of
the Trust agreement by an acknowledged Instrument delivered to the Grantor.
Attached is the acknowledged instrument for the addition and deletion of the beneficiaries, signed by the
trustees and the grantor.
Cynthia Rodriguez
2/1/117 11:23 AM
Amended list of beneficiaries attached to include
M. Research is also attached.
Cynthia Rodriguez
1/30/117 2:45 PM
Jason Shames advised on1/03/2017 that fully executed addibon of beneficiary forms by the trustee, along with
acknowledgment signature from the grantor are what rs needed to make changes to the beneficiaries of the
trust.
Cynthia Rodriguez
12)19/116 5:02 PM
Attached are the supporting documents for the addition/deletion of bents of this trust.
ONSHORE APPROVALS
Client Facing Professional (CFP):
tern sohrab
,Signature)
tit; sohrab
12/15/2016
Office Director/Business Head
Armen Brash
(Signature)
Armen Brash
12/15/2016
Regional Office Director:
(Signature)
AML Cosiness Risk:
(Signature)
AML Compliance
Ricardo Mendoza
Yoonsun Chung
(Signature)
Ricardo Mendoza
Yoonsun Chung
212,2017
2/2/2017
LATAM/INTERNATIONAL APPROVALS
Client Facing Professional (CFP):
(Signature)
Account Manager:
(Signature)
Global Market Team Head
(GFITH)/Sutrilarket Team Head
(51411g:
(Signature)
NIL Business Risk:
(Signature)
AN". Can::
i'l
(SignatLre,
PRIVATE WEALTH MANAGEMENT POLICY STATEMENT: Deutsche Bank Private Wealth Management
(PWM)worlaWide is committed to professionally serve the interests of lts clients. To do so, Client Facing
Projessionals)0) ((VP's) should establish and maintain business relationships only with persons who satisfy our high
standards ofsuitability, background and character. Due diligence obtained on the client must be appropriately
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documented by the CFP. It is the responsibility ofCFP'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 of my knowledge and belief the above
information is correct and up to date. 1 confirm that I have no suspicions relating to the money laundering or unethical
activities on the part of the client(s) and that 1 have followed all the procedures relating to account opening as
described in the PWM Americas Procedures and the PIM Global KYC Policy
1) Client Facing Professionals (CFP's) include: Relationship Managers. Wealth Advisors. Product Officers, Brokers,
Client Managers, etc.
Deutsche Bank Americas New York rA
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| Filename | EFTA00167035.pdf |
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