EFTA00167111.pdf

KYC Print Page 1 of 10 DB PWM GLOBAL KYC/NCA: PART A KYC Case S : 01790724 One sheet must be established per relationship list all accounts included in the relationshi 1. Relationship Details Relationship Name: SOUTHERN FINANCIAL RELATIONSHW:0000O443290 I Bed"ng Center: I New York Relationship Manager: stewed *Meld O New PWM Relationship Ilia Existing PWM Relationship Relationship to PWM: If existing, please Indicate since when the relationship exists, provide reason for new profile and attach old profile • • *This KYC is a periodic review for high risk remediation• • • Original KYC1161376 J Client Referral • RM Prospect O Intermediary/FIN • Other Source (CIa, et.) Mow Was the aient(s) Introduced) How long has the RM personally known the cents please provide details (e.g. name of r rce, rs RM personalty has known dent, etc.): Stewart Oldfldd and Cynthia Rodriguez contacted and on 6/23/2017 to confkm f there are any material changes to tltnr joint Does Deutsche Bank pay a retrocession or similar Dyes I I No compensation to a third party for the introduction of this relabOrdhlp? af Yes, describe) List all existing and new accounts nvolved in this relationship Legal Entity Account(s) Account Name / Number Opening Date (Intended/actual) 1 2 and Deposit 12/16/2013 Who n the primary contact person for the RN) (Note: This person needs to have signatory rights and/or information right for the accounts.): Prefetrefl method of contact to peone no , fax no., c-pair acl.lres, etc ) Status : 6. Approved https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9DiSce... 7/30/2019 CONFIDENTIAL — PURSUANT TO FED. R. GRIM. P. 6(e) DB-SONY-0002885 EFTA_00016359 EFTA00167111 KYC Print Page 2 of 10 One sheet must be established for each account to be opened 2. Account Ownership Summary Account Name: and Deposit Acct Number Of . avaaaNel. Account Manager: stover oldfieki What is the purpose of the account (e.g. portfolio man e ry account custody services, long-term investment payment/expense ou acc nt)) Checking account for the daily use of and Indicate from where the assets are expected to arrive' RI DB Group: Same Booking Center (Indicate account number): 0 06 Group: Other Booking Center (Indicate DB location and account details): O Other Institution - (Indicate name & locabon): O Physical Deposit (specify cash, securibes, cheques, ...): What is the expected size and frequency of regular inflows and out/lows for the account (indicate estimated number and volume per month)' 0-4 inficnn and outflows per month ranging from $100 to S1500 What b the expected volume of assets and currency for the account approx. 90 days after openisp 1 10000 I Currency I USD What b the expected volume of assets and currency for the account approx. one year after opening? 14379.40 I Currency I USD Doesfyill the client Nye Assets Under Management (AuM) within DB under Eta. 3M' O yes 0 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 tab account (> 1 can be selected). • If none of the check boxes apply, describe the partys relation to the account In the "Other column. • Alysys describe the relationsMp between the parties in the last column. • Please drill dorm to the unmate/underlyng Elenefkial Owner(s). _egal inbtyof Descripti Source of Wealth required arses fated this count AccounWIC Holder OwnerTrust Sabo/ of / Founder of Foundation Jltimate Beneficialor Owner SignatornimitedPinancial Full POA ?OA Intern edlary5harehokierSeprescntabve (AM) tIgnificant 1>•25%) Ion-PIC entity indicate ownership k) _egal Grantor/Senor Founding Donor Other 'please Sescribe 'trier roles and/or nchcate elatcriship en rtes) 00 Ed O O 0 0 OO f-- E 2 O 0 2 O • El a O O c E Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-0IN30000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002886 EFTA_000 16360 EFTA00167112 KYC Print Page 3 of 10 One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summary_ 34. Individual Details (for all parties) Individual's Name. Date of Birth: Country of Residence Country of Citizenship: Address of primary residence: Has dent resided outside of Ms/her country of nallonalty fa 5 years or niece? No Elyosn Profession,OccuPabon Tax ID / SSN: Current Employer: Posilionfiltle/Rank: Address of employer: Does the person work as senio executive of a CO-recognized regulated entity in the financial ndustryr or an entity listed on a OB-recognised exchange' (Not applicable for operating nutlet O Yes 0 No Is the individual a Politically Exposed Person (PEP)(/ Yes, describe) O Yes g!I No To the best of your knowledge, is the Individual related to an employee of the 08 group/(r/ Faint or FnencIsixA describe ) 0 Family 0 Friendship Ri None To the best of your knowledge, is the indndual party to a non-banking relabaishp with Deutsche Bank (e.g., external legal counsel, client referral source, supplier of goods cc services)af Yes, describe I ❑O Yes TA No If applicable, indicate which bank cflicers have met the person: Indicate where and Wien the client meets (s) took place: Rank Officer Name(s) Bank Office: Client Private Domicile: Client Place of Business: Other location (specify): Date: Paul Morris O O 0 12/3/2013 O O O O O LI OWealin Debits 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 Individual's Business: homemaker Primary Country of source of wealth/source of Funds? Primary industry of source of Wealth/Source of Funds> Summarize Source of Wealth: 00ther: OBusiness Owner O Salary/Eamings i i i Investment O Inheritance/Gifts Further Descrte Source of Wealth now did family accumulate wnith'For countries of mast activities, important Estmated Annual Income($): /Detail the history of weath business owners, how Ion business partners.) for each of the sources: (e.g. For trusts, how did senior accumulate in business how ma e ees level cf &Rabe 7 Indicate Estimated amount of investable assets($): wealth? For inheritance, of business <$1 MM Estimated Net Worth($): cS1 MM Amount of assets planned to invest with PWM($): 20,000.00 Other Known Francial Institutions: Insbtution: I )PMoegan I Caw": I USA 'Est. Assets Under Mgt 160,000.00 Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-0IN30000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002887 EFTA_00016361 EFTA00167113 KYC Print Page 4 of 10 lnsbtubon: Country Est Assets Under Mgt Institution: Country: Est Assets Under Mgt Mease indicate the family situabon of the individual (marital stahm. other family members, etc.)'. Manned to Karyna Shullak Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-OIN30000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002888 EFTA_000 16362 EFTA00167114 KYC Print Page 5 of 10 One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Somme 3A. Individual Details (for all parties) Individual's Name. Date of Birth: Country of Residence: Country of Citizenship: Address ii primary residence Has dent resided outside of his/her country of natiOnalty fa 5 years or wee? Oyes 74 No Profession/Occupation: Tax ID / SSN: Current Employer: PosItloWlble/Rank: Address of employer: Does the person work as senio executive of a DO-recognized regulated entity n the financial ndusby' or an entity listed on a 06-recognised exchange? (Not applkable for operating nabs O yes 0 No Is the individual a Politically Exposed Person (PEP)(/ Yes, describe) O Yes WI No To the best of your knowledge, is the Individual related to an employee of the DB group>O Fn)' or (nencIsixA describe) 0 Family 0 Friendship R1None To the best of your knowledge, is the individual party to a non-banking relabcnshp with Deutsche Bank (e.g., external legal counsel, client referral source, supplier of goods cc services)'af l'es,desrnb e I TA O Yes No If applicable, indicate which bank officers have met the person: Indicate Mitre and Wien the client meethig(s) took place: Bank Officer Name(s) Bank Office: Client Private Domicile: Client Place of Business: Other locabon (specify): Date: Stewart Odheld O O PI 6/23/2017 O O O O O LI El Wealth Debits 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 swell description as indicated in Section 2) Nature of the Individuals Business: interior design Primary Country of source of wealth/source of Funds' Primary industry of source of Wealdi/Source of Funds' Summarize Source of Wealth: D Business Owner [0 Salary/Eamings 00ther: i i i Investment O Inhentance/Gifts Further Descrbe Source of Wealth how did family accumulate wealth>For countries of ma a adavilies im Estimated Annual Income(S): /Detail the history of business owners, ortant business artners.) Her weath for each of the sources: (e.g. For trusts, how did senior- accumulate wealth? For inheritance, how long In business, how many employees, level of profitability' Indicate type of business, annual Income S approximately $150k with salary, bonus, and COMMISSICOS. 150,000.00 Estenated amount of investable assets($): :41 Mil Estimated Net Worth($): <$1 SW Amount of assets planned to invest wels PWM($): 2,000.00 Other Known Financial Institution: Institution: db County: Coun rasa Est As Assets Under Mgt 2,000.00 Institution: IP Morgan Chase Country. USA Est Assets Under Mgt 2,000.00 Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-0IN30000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002889 EFTA_00016363 EFTA00167115 KYC Print Page 6 of 10 Country: Est Assets Under Mgt please indicate the family situation or the Individual (marital status, other Varney members, etc.): Flamed to • Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-OIN30000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002890 EFTA_000 16364 EFTA00167116 KYC Print Page 7 of 10 DB PWM GLOBAL KYC/NCA: US/LatAm/Int'l PART B Relationship Name SOUTHERN FINANCIAL RELATIONSHIP Risk Rating Comments: Booker° Center O NY/Offsh cce 0 Offshore • Moderate Yososun Chung re' ..I NY Fr ..a High Risk Risk (Compliance Signature) O DB Employee O DB Managed PIC O DB is Trustee/Co-Trustee O Bearer Shares 4. Attachments A. Type of Photo ID Provided Tal Drivers License • Passport • Nabonal/State ID O Other Checklist <I names (individuals and/cr entitles) that were submitted for database searches is B. • yes - No attached C. Please Indicate the results cf the database searches performed RDC searches corrokte 2 Yes • No negative results found O Yes 0 No PCR checks complete 2 Yes O No negative results found O Yes 0 No OFAC checks complete 2 Yes El No negative results found O Yes 0 No BIS searches complete (Lexis/Nexis, Pectin, Reuters, Dow Jones. MB) 0 yes • No negative results found • YeS 0 No Denial Orders checks complete 2 Yes ONo negative results found Oyes WI No Martindale-Hubbell searched (Lawyers/Law Firms only) 0 Yes 2 No negative results found • Yes ONo Please summarize any negative results from the database searches indicated above: No Negative Media r Court case ref for a personal injury and is a false positive as the n KYC resales in red has no cu . • D. No Negative Media No Court Cases E. To the best of your knowledge, has the client ever been convicted of a criminal offense' El Yes 5 No To the best of your knowledge, has the customer ever been kwolved in any past litigation against Deutsche Bank AG or any of ft suburbs nes or is the customer threatening litigation against F. El Yes ra No Deutsche Bank AG or any of is subsidiaries, (If Yes, prove,* details below and contact Quakty Mist. (Catemant7)or the Regulatory Control Group and nobly Con:seance immediately) Does the client or related party have any financial or other aSSOCIabeel / oteractons within G. countries or regents sanctionedby the Office of Foreign ASSets Control (CCAQ' Il Yes R No H. Does the client a related party have any financial or other association/ nteractions within high O yes 2 No risk countries' I. Corporate Documentation Attached (Legal Entitles Only) S Yes 0 No MNat ApplKable J. Undisclosed Principal Form Complete (Intermediaries Only) 0 Yes ONO :.% Not Applicable K. If Lexis/Nexis Search Results, Corporate Documents or Other Supporting Documentation is not In English, please provIde an EngIsh summary of the nature/contents of the non English Documentation: L Special Risk Factors Does the account have Nexus to Special Risk Countries' O Yes 0 No Is the account structure unusually complex' Dyes trs. No https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9DiSce... 7/30/2019 CONFIDENTIAL — PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002891 EFTA_000 16365 EFTA00167117 KYC Print Page 8 of 10 Is there any Ind Kabon the client set up a non operating company eypressly for the purpose of transferring shares to third parties' ❑yes No Is there any indrcation the could be a prohibited business relationship' Dyes No Ate the bearer shares identified subject to acceptable controls' ❑Yes EZ No Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-OIN30000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002892 EFTA_000 16366 EFTA00167118 KYC Print Page 9 of 10 M. Case Comments Created By Date Comments Kshiti; c n 7 27 117 5 0G PM The account holders have been clients of DB since 2013. Below are the reasons why we were comfortable anon:Mau this high risk KYC remediatlon - information and supporbng documents required by our MIL Policy were provided and reviewed; and as a we have an understanding of the structure of the accountholders, their purpose, the purpose of the counts and expected transacbon activity The account holders' (M and source of wealth and source of funds were cienny detailed and appears plausible Our review dad 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 net find the names searched to be on any ncoons lists. ONSHORE APPROVALS Client Facing Professional (CFP): steivart °Infield (Signature) stewart oldheld 7/20/2017 Office Director/Business Head: Andre:: F Gallivan (Signature) Andrew F Caravan 7/25/2017 Regional Office Director: (Signature) MIL Business Risk: (Signature) AML Compliance: Kshitij Golani Ycxxisun Chung (Signature) Kshibj Golan, Yoontun Chung 7/27/2017 7/27/2017 LATAM/INTERNATIONAL APPROVALS Client Facing Professional (CFP). (Signature) Account Manage: (Signature) Global Market Team Head Gl" t Sub-Market Team Head st= (Signature) MIL Business Risk: (Signature) NIL Compliance: (Signature) PRIVATE WEALTH MANAGEMENT POLICY STATEMENT: Deutsche Bank Private Wealth Management (P0%!) worldwide is committed to professionally serve the interests ofits clients. To do so, Client Facing Professionals IN (CFP 's) should establish and maintain business relationships only with persons who misfit our high standards ofsuitability, background and character. Due diligence obtained on the client must be appropriately documented by the CFP. It is the responsibility of CFP's to demonstrate that they know their client both at the Imps://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid-OIN30000000D9Di&e... 7/30/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0002893 EFTA_000 16367 EFTA00167119 KYC Print Page 10 of 10 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 dale. I confirm that I have no suspicions relating to the money laundering or unethical activities on the pan of the client(s) and that I have followed all the procedures relating to account opening as described in the PWM Americas Procedures and the PWM Global KYC Policy (I) Client Facing Professionals (CFP's) include: Relationship Managers, Wealth Advisors. Product Officers. Brokers. Client Managers, etc. Deutsche Bank Americas New York https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9DiSce... 7/30/2019 CONFIDENTIAL — PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0002894 EFTA_00016368 EFTA00167120