Deutsche Bank KYC file for a private client's Neptune LLC accounts, 2013

KYC Print¶

Page 1 of 11¶

DB PWM GLOBAL KYC/NCA: PART A¶

1. Relationship Details¶

Relationship Name: SOUTHERN FINANCIAL RELATIONSHIP | Booking Center: | New York¶

Relationship Manager: Paul Morris¶

Relationship to PWM:¶

• ✓ New PWM Relationship
• □ Existing PWM Relationship

If existing, please indicate since when the relationship exists, provide reason for new profile and attach old profile:¶

How Was the Client(s) Introduced? How long has the RM personally known the client?¶

• ☐ Client Referral
• ☑ RM Prospect
• ☐ Intermediary/FIM
• ☐ Other Source (CIB, etc.)

Please provide details (e.g. name of referral source, how many years RM personally has known client, etc.): Jeffrey Epstein is a current client of the Bank. Wants to open a new account. Introduction details of Paul and Jeffrey: Jeffrey Epstein was a client of Paul’s at JP Morgan. Paul and Jeffrey Epstein had a mutual friend/colleague who introduced them while Paul was at JP Morgan. Over the course of a few meetings Paul was able to get Jeffrey to bring some of his funds over to Deutsche Bank¶

Does Deutsche Bank pay a retrocession or similar compensation to a third party for the introduction of this relationship?¶

• ☐ Yes
• ☑ No

(If Yes, describe):¶

List all existing and new accounts involved in this relationship¶

Legal Entity Account(s)	Account Name / Number	Opening Date (intended/actual)
1	Neptune LLC	10/16/2013
2	Neptune LLC — Money Market	10/16/2013

Who is the primary contact person for the RM? (Note: This person needs to have signatory rights and/or information right for the accounts.):¶

• Harry Beller | Preferred method of contact (indicate phone no., fax no., e-mail address, etc.): |

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7/30/2019¶

DB-SDNY-0002596¶

EFTA_00016070¶

EFTA00166822¶

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One sheet must be established for each account to be opened¶

2. Account Ownership Summary
Account Name:				Neptune LLC				Acct. Number ("if available")
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)? Checking account used for the daily needs of running Jeffrey Epstein's home in NYC.
Indicate from where the assets are expected to arrive? ☐ DB Group: Same Booking Center (indicate account number): ☐ DB Group: Other Booking Center (indicate DB location and account details): ☑ Other Institution (Indicate name & location): JPMorgan. New York ☐ Physical Deposits (specify cash, securities, cheques, ...)
What is the expected size and frequency of regular inflows and outflows for the account (indicate estimated number and volume per month)? Roughly 10 inflows 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 opening?						5000			Currency		USD
What is the expected volume of assets and currency for the account approx. one year after opening?						10000			Currency		USD
Does/will the client have Assets Under Management (AuM) within DB under Eur. 3M?						☐ Yes ☑ 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 column. • Please drill down to the ultimate/underlying Beneficial Owner(s).
Legal Entity	Description of Source or Wealth Required	Parties related to this account	Account Holder	PIC Owner	Settler of Trust / Pounder of Foundation	Ultimate Beneficial Owner	Signatory for Full POA	Limited POA	Financial Intermediary (FIM)	Significant Shareholder (> 25%) Non-PIC entity (indicate ownership %)	Legal Representative	Grantor/Settter	Founding Donor	Other (please describe other roles and/or indicate relationship between parties)
1	✓	✓	Neptune LLC	✓	✓	✓	✓	✓	✓		✓	✓	✓
2	□	✓	Jeffrey Epstein	□	□	□	✓	□	□		□	□	□
3	□	□	Harry Beller	□	□	□	✓	□	□		□	□	□

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7/30/2019¶

DB-SDNY-0002597¶

| EFTA_00016071 | | :--- | :--- |¶

This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text: “EFTA_00016071”.¶

EFTA00166823¶

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2. Account Ownership Summary¶

Account Name:	Neptune LLC — Money Market	Acct. Number (if available):
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)? Money Market to hold funds necessary to run the costs associated with Jeffrey Epstein’s NYC home¶

Indicate from where the assets are expected to arrive?¶

• DB Group: Same Booking Center (indicate account number):
• DB Group: Other Booking Center (indicate DB location and account details):
• Other Institution (Indicate name & location): JPMorgan. NYC
• Physical Deposits (specify cash, securities, cheques, …):

What is the expected size and frequency of regular inflows and outflows for the account (indicate estimated number and volume per month)? Roughly 1-3 inflows 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 opening?¶

5000 Currency USD¶

What is the expected volume of assets and currency for the account approx. one year after opening?¶

10,000 Currency USD¶

Does/will the client have Assets Under Management (AuM) within DB under Eur. 3M?¶

☐ Yes ☑ 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 column.
• Please drill down to the ultimate/underlying Beneficial Owner(s).

Legal Entity	Description of Source or Wealth Required	Parties related to this account	Account Holder	PIC Owner	Settler of Trust / Founder of Foundation	Ultimate Beneficial Owner	Signatory for Full POA	Limited POA	Financial Intermediary (FIM)	Significant Shareholder (>=25%) Non-PIC entity (indicate ownership %)	Legal Representative	Grantor/Settlement	Founding Donor	Other (please describe other roles and/or indicate relationship between parties)

1. ✓ ✓ ✓ Neptune, LLC
2. □ □ Jeffrey Epstein
3. □ □ Harry Beller

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CONFIDENTIAL-PURSUANT TO FED.R.CRIM.P.6(e)	DB-SDNY-0002

DB-SDNY-0002598¶

EFTA_00016072¶

EFTA00166824¶

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One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summary¶

3A. Individual Details (for all parties)
Individual's Name:	Jeffrey Epstein			Date of Birth:		1/20/1953
Country of Residence:	USVI			Country of Citizenship:		USA
Address of primary residence:	Little Saint James Saint Thomas 00802 US Virgin Islands			Has client resided outside of his/her country of nationality for 5 years or more?		□ Yes ☑ No
Profession/Occupation:	Self Empolyed			Tax ID / SSN:
Current Employer:	Southern Financial LLC			Position/Title/Rank:		President
Address of employer:	6100 Red Hook Quarter B3 St. Thomas USVI 00802
Does the person work as senior executive of a DB-recognized regulated entity in the financial industry? or an entity listed on a DB-recognised exchange? (Not applicable for operating entities)				□ Yes ☑ No
Is the individual a Politically Exposed Person (PEP)?(if Yes, describe)				□ Yes ☑ No
To the best of your knowledge, is the individual related to an employee of the DB group?(if Family or Friendship, describe)				□ Family □ Friendship ☑ None
To the best of your knowledge, is the individual party to a non-banking relationship with Deutsche Bank (e.g., external legal counsel, client referral source, supplier of goods or services)?(if Yes, describe)				□ Yes ☑ 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 (specify):		Date:
Paul Morris		□	□	☑			9/13/2013
		□	□	□
		□	□	□

3B. Wealth Details(Only for parties requiring source of wealth description as indicated in Section 2)
Nature of the Individual's Business:			Private investments
Primary Country of source of wealth/source of Funds?
Primary industry of source of Wealth/Source of Funds?
Summarize Source of Wealth:			Business Owner Salary/Earnings Investment Inheritance/Gifts Other:
Further Describe Source of Wealth /Detail the history of wealth for each of the sources:(e.g. For trusts, how did settlor 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.) Epstein began his financial career in 1976 as an options trader at Bear Stearns and became a partner in 1980.In 1982,Epstein founded his own financial management firm,J.Epstein&Co.,managing the assets of clients with more than a billion 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.All of his clients were anonymous except for the very wealthy businessman Leslie Wexner.His wealth has come from his days at Bear Stearns and his financial management firms
Estimated Annual Income($):	10,000,000.00		Estimated amount of investable assets($):		$50 MM-100 MM
Estimated Net Worth($):	$100 MM-500 MM		Amount of assets planned to invest with PWM($):
Other Known Financial Institutions:
Institution:	JPMorgan		Country:	USA	Est. Assets Under Mgt:	200,000,000.00

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CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)	DB-SDNY-00

EFTA_00016073¶

EFTA00166825¶

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Institution:		Country:		Est. Assets Under Mgt:
Institution:		Country:		Est. Assets Under Mgt:
Please indicate the family situation of the individual(marital status, other family members, etc.)：

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CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)	DB-SDNY-000

EFTA_00016074¶

EFTA00166826¶

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One sheet must be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summary¶

3A. Individual Details (for all parties)
Individual's Name:	Harry Beller		Date of Birth:
Country of Residence:	USA		Country of Citizenship:		USA
Address of primary residence:			Has client resided outside of his/her country of nationality for 5 years or more?		□ Yes ✔ No
Profession/Occupation:	Accountant		Tax ID / SSN:
Current Employer:	HBRK Associates		Position/Title/Rank:
Address of employer:	575 Lexington Ave, 4th Fl New York NY USA 10022
Does the person work as senior executive of a DB-recognized regulated entity in the financial industry? or an entity listed on a DB-recognised exchange? (Not applicable for operating entities)
Is the individual a Politically Exposed Person (PEP)?(if Yes, describe)
To the best of your knowledge, is the individual related to an employee of the DB group?(if Family or Friendship, describe)
To the best of your knowledge, is the individual party to a non-banking relationship with Deutsche Bank (e.g., external legal counsel, client referral source, supplier of goods or services)?(if Yes, describe)
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 (specify):	Date:
Paul Morris		□	□	✔		9/13/2013
		□	□	□
		□	□	□

3B. Wealth Details(Only for parties requiring source of wealth description as indicated in Section 2)
Nature of the Individual's Business:
Primary Country of source of wealth/source of Funds?
Primary industry of source of Wealth/Source of Funds?
Summarize Source of Wealth:				Business Owner Salary/Earnings Investment Inheritance/Gifts Other:
Further Describe Source of Wealth /Detail the history of wealth for each of the sources:(e.g. For trusts, how did settlor 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 Annual Income($):				Estimated amount of investable assets($):
Estimated Net Worth($):				Amount of assets planned to invest with PWM($):
Other Known Financial Institutions:
Institution:			Country:				Est. Assets Under Mgt:
Institution:			Country:				Est. Assets Under Mgt:
Institution:			Country:				Est. Assets Under Mgt:

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CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)	DB-SDNY-000

DB-SDNY-0002601¶

EFTA_00016075¶

EFTA00166827¶

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Please indicate the family situation of the individual(marital status,other family members,etc.)：

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:	Neptune, LLC
Type of Entity:	Foundation/Association Trust Company Estate Partnership		Purpose of Entity:	Private Investment Philanthropic/Charitable Commercial
Type of Entity Other(specify):			Purpose of Entity Other(specify):
Country of incorporation/registration:	USA		Date of incorporation/registration:	12/21/2011
Volker Status:			Volker Flag:
Address(city, street, post code):	6100 Red Hook, Quarter B3 St, Thomas 00802 USVI		U.S. TIN/EIN:
Provide a description of the entity's organizational structure, its ownership structure and its Top Management. For trusts/foundations, include information about revocability, settlor and beneficiaries, etc.:Single member LLC. Jeffrey Epstein is the sole memberPlease indicate how ownership of the legal entity is reflected: Single member LLC. Capital contribution of $1000 was made by Jeffrey Epstein who is the sole member
Special attention: Bearer Shares - Indicate where shares are custodied:
Describe the chain from the direct owner of the entity to the ultimate beneficial owner(if not the same persons). Single member LLC. Jeffrey Epstein is the sole memberTo the best 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 services)?YesNo
Describe Nature of Entity's Primary Business and Investment Activities
Nature of the business:		This LLC was formed to hold the funds necessary to cover the costs and taxes associated with running Jeffrey Epstein's NYC home
Countries where business is transacted:		USA
Number of employees:		1

3D. Wealth Profile(Only for parties requiring source of wealth description as indicated in Section 2)
Primary 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 assets/liabilities):This LLC is funded my contributions made by Jeffrey Epstein.
Estimated gross receipts p.a.($):
Estimated net profit p.a.($):
Estimated investable assets($):			<$1 MM
Potential Amount to be invested with PWM($):			20,000.00
Other Known Financial Institutions:
Institution:	JPMorgan	Country:		USA	Est. Assets Under Mgt:	20,000.00
Institution:		Country:			Est. Assets Under Mgt:
Institution:		Country:			Est. Assets Under Mgt:

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CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)	DB-SDNY-000

DB-SDNY-0002602¶

EFTA_00016076¶

EFTA00166828¶

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DB PWM GLOBAL KYC/NCA: US/LatAm/Int’l PART B¶

Relationship Name	SOUTHERN FINANCIAL RELATIONSHIP
Risk Rating Comments:
Booking Center	NY	NY/Offshore	Offshore		Moderate Risk	High Risk	Janice Franklin
(Compliance Signature)
DB Employee	DB Managed PIC			DB is Trustee/Co-Trustee				Bearer Shares

4. Attachments¶

A. Type of Photo ID Provided ☑ Drivers License ☑ Passport ☐ National/State ID ☐ Other¶

B. Checklist of names (individuals and/or entities) that were submitted for database searches is attached ☑ Yes ☐ No¶

C. Please indicate the results of the database searches performed¶

RDC searches complete ☑ Yes ☐ No negative results found ☑ Yes ☐ No¶

PCR checks complete ☑ Yes ☐ No negative results found ☑ Yes ☐ No¶

OFAC checks complete ☑ Yes ☐ No negative results found ☑ Yes ☐ No¶

BIS searches complete (Lexis/Nexix, Factiva, Reuters, Dow Jones, DBB) ☑ Yes ☐ No negative results found ☑ Yes ☐ No¶

Denial Orders checks complete ☑ Yes ☐ No negative results found ☑ Yes ☐ No¶

Martindale-Hubbell searched (Lawyers/Law Firms only) ☑ Yes ☐ No negative results found ☑ Yes ☐ No¶

Please summarize any negative results from the database searches indicated above: NEPTUNE LLC: See attached AML Clearance — The RDC alert was a false hit Negative Media: All negative media is not our client. All negative media either predates our client’s formation (2011) or is another LLC. Our Neptune LLC is a single member LLC that runs the operations of a home¶

JEFFREY EPSTEIN: D. See KYC #01082293 and #01121718 for previous KYC approval and all pertaining documents¶

HARRY BELLER: Negative Media: Not our client. All negative media pertains to an environmental microbiologist. Our client is an accountant Court Cases: #1 Dispensed in 1987 All other cases are not our client. The other court cases refer to a Dr. Harry Beller. Our client is an accountant¶

E. To the best of your knowledge, has the client ever been convicted of a criminal offense? ☑ Yes ☐ No¶

To the best of your knowledge, has the customer ever been involved in any part litigation against Deutsche Bank AG or any of its subsidiaries or is the customer threatening litigation against Deutsche Bank AG or any of its subsidiaries? (If Yes, provide details below and contact Quality Mgt. (LabAm/Intl) or the Regulatory Control Group and notify Compliance immediately)¶

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 (OFAC)? ☑ Yes ☐ No¶

H. Does the client or related party have any financial or other association / interactions within high risk countries?¶

I. Corporate Documentation Attached (Legal Entities Only) ☑ Yes ☐ No Not Applicable¶

J. Undisclosed Principal Form Complete (Intermediaries Only) ☑ Yes ☐ No Not Applicable¶

K. If Lexis/Nexis Search Results, Corporate Documents or Other Supporting Documentation is not in English, please provide an English summary of the nature/content of the non-English Documentation:¶

L. Special Risk Factors¶

Does the account have Nexus to Special Risk Countries? ☑ Yes ☐ No¶

Is the account structure unusually complex?¶

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CONFIDENTIAL-PURSUANT TO FED.R.CRIM.P.6(e)	DB-SDNY-000

EFTA_00016077¶

EFTA00166829¶

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	□Yes	☑No
Is there any indication the client set up a non operating company expressly for the purpose of transferring shares to third parties?	□Yes	☑No
Is there any indication this could be a prohibited business relationship?	□Yes	☑No
Are the bearer shares identified subject to acceptable controls?	□Yes	☑No

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DB-SDNY-0002604¶

EFTA_00016078¶

EFTA00166830¶

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M. Case Comments

No records to display.

ONSHORE APPROVALS
Client Facing Professional(CFP):	Paul Morris	(Signature) Paul Morris	10/8/2013
Office Director/Business Head:	Brian M. Biggar	(Signature) Brian M. Biggar	10/8/2013
Regional Office Director:		(Signature)
AML Business Risk:		(Signature)
AML Compliance:	Jacqueline Lightbody	(Signature)	10/17/2013
		Jacqueline Lightbody
	Janice Franklin	Janice Franklin	10/17/2013

LATAM/INTERNATIONAL APPROVALS
Client Facing Professional(CFP):		(Signature)
Account Manager:		(Signature)
Global Market Team Head(GMTH)/Sub-Market Team Head(SMTH):		(Signature)
AML Business Risk:		(Signature)
AML Compliance:		(Signature)

PRIVATE WEALTH MANAGEMENT POLICY STATEMENT: Deutsche Bank Private Wealth Management (PWM) worldwide is committed to professionally serve the interests of its clients. To do so, Client Facing Professionals1(1) (CFP’s) should establish and maintain business relationships only with persons who satisfy our high standards of suitability, 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 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. I confirm that I have no suspicions relating to the money laundering or unethical activities on the part 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¶

(1) Client Facing Professionals (CFP’s) include: Relationship Managers, Wealth Advisors, Product Officers, Brokers, Client Managers, etc.¶

Deutsche Bank Americas New York¶

URL	Date
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CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)	DB-SDNY-0002605

EFTA_00016079¶

EFTA00166831¶

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EFTA00166832¶