KYC Print Page 1 of 12 DB PWM GLOBAL KYC/NCA: PART A # One sheet must be established per relationship - list all accounts included in the relationship ## 1. Relationship Details | Relationship Name: | EPSTEIN, JEFFREY RELATIONSHIP | Booking Center: | New York | | :--- | :--- | :--- | :--- | | Relationship Manager: | Stewart Oldfield | | | | 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: ***This KYC is a periodic review for high risk remediation*** Original KYC1133377 | | 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.): Stew Oldfield reached out to Rich Kahn and Darren Indyke on 7/7/2017 to confirm material changes to the accounts. Rich Kahn confirms that he is now the sole owner and signor of HBRK Associates. His main source of wealth derives from this company. Darren confirms no material changes to his PLLC | | 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 | HBRK Associates, Inc- Deposit | 11/1/2013 | | 2 | Darren K. Indyke PLC- Deposit | 11/1/2013 | Who is the primary contact person for the RM? (Note: This person needs to have signature rights and/or information right for the accounts.): | | Preferred method of contact (indicate phone no., fax no., e-mail address, etc.): | CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0000246 USAO 001209 7/11/2019 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... EFTA_00019119 EFTA00168866 KYC Print Page 2 of 12 One sheet must be established for each account to be opened
| 2. Account Ownership Summary | ||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Account Name: | HBRK Associates, Inc- Deposit | Acct. Number (if available): | ||||||||||||
| Account Manager: | stewart oldfield | |||||||||||||
| What is the purpose of the account (e.g. portfolio management, advisory account, custody services, long-term investment, payment/expense account)? Checking account to hold funds for daily use for the company. | ||||||||||||||
| 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): ☐ 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)?: 0-15 inflows/outflows between 1k and 6k on a monthly basis | ||||||||||||||
| What is the expected volume of assets and currency for the account approx. 90 days after opening? | 100000 | Currency | USD | |||||||||||
| What is the expected volume of assets and currency for the account approx. one year after opening? | 163601.48 | 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 of Wealth required | Parties related to this account | Account Holder | PIC Owner | Settler of Trust / Founder of Foundation | Ultimate Beneficial Owner | Signatory or Full POA | Limited POA | Financial Intermediary (FIM) | Significant Shareholder (>=25%) Non-PIC entity (indicate ownership %) | Legal Representative | Grantor/Settlor | Founding Donor | Other (please describe other roles and/or indicate relationship between parties) |
| 1 | ✓ | ✓ | HBRK Associates, Inc | ✓ | □ | □ | □ | □ | □ | □ | □ | □ | □ | |
| 2 | □ | ✓ | Richard D. Kahn | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ | |
| 2. Account Ownership Summary | ||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Account Name: | Darren K. Indyke PLLC- Deposit | Acct. Number (if available) | ||||||||||||
| Account Manager: | stewart oldfield | |||||||||||||
| What is the purpose of the account (e.g. portfolio management, advisory account, custody services, long-term investment, payment/expense account)? Checking account for the daily use of the this law firm | ||||||||||||||
| 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): ☐ 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)?: 0-15 inflows/outflows between 1k and 15k on a monthly basis | ||||||||||||||
| What is the expected volume of assets and currency for the account approx. 90 days after opening? | 100500 | Currency | USD | |||||||||||
| What is the expected volume of assets and currency for the account approx. one year after opening? | 295086.86 | 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 of Wealth required | Parties related to this account. | Account Holder | PIC Owner | Settler of Trust / Founder of Foundation | Ultimate Beneficiary Owner | Signatory or Full POA | Limited POA | Financial Intermediary (FIM) | Significant Shareholder (>=25%) Non-PIC entity (indicate ownership %) | Legal Representative | Grantor/Settler | Founding Donor | Other (please describe other roles and/or indicate relationship between parties) |
| 1 | ☐ | ✓ | Darren K. Indyke | ☐ | ☐ | ☐ | ✓ | ☐ | ☐ | ☐ | ☐ | ☐ | ☐ | |
| 2 | ✓ | ✓ | Darren K. Indyke PLLC | ✓ | ☐ | ☐ | ☐ | ☐ | ☐ | ☐ | ☐ | ☐ | ☐ | |
| Institution: | Country: | Est. Assets Under Mgt: | |||
| Please indicate the family situation of the individual (marital status, other family members, etc.): | |||||
| Institution: | Country: | Est. Assets Under Mgt: | |||
| Please indicate the family situation of the individual (marital status, other family members, etc.): | |||||
| 3C. Legal Entity Details(For all Legal Entities) | |||
| Legal Entity Name: | Darren K. Indyke PLLC | ||
| 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:9/5/2008 | |
| Volcker Status: | Determination Required | Volcker Flag:No | |
| Address(city, street, post code): | 575 Lexington Avenue New York NY 10022 United States | U.S. TIN/EIN: | |
| Please indicate how ownership of the legal entity is reflected: Single member PLLC with Darren K. Indyke as the sole member and owner | |||
| 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 PLLC with Darren K. Indyke as the sole member and owner | |||
| To 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: | Law practice.This is Darren Indyke's private law firm. | ||
| 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):Assets come from the rates he charges clients for his law services | ||||||
| Estimated gross receipts p.a.( $ ): | 300,000.00 | |||||
| Estimated net profit p.a.( $ ): | 200,000.00 | |||||
| Estimated investable assets( $ ): | <$1 MM | |||||
| Potential Amount to be invested with PWM( $ ): | 100,000.00 | |||||
| Other Known Financial Institutions: | ||||||
| Institution: | JPMorgan | Country: | USA | Est. Assets Under Mgt: | 500,000.00 | |
| Institution: | Country: | Est. Assets Under Mgt: | ||||
| Institution: | Country: | Est. Assets Under Mgt: | ||||
| Legal Entity Name: HBRK Associates, Inc. | ||||
|---|---|---|---|---|
| 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: | 8/29/2008 | |
| Volcker Status: | Determination Required | Volcker Flag: | No | |
| Address (city, street, post code): | 575 Lexington Avenue, 4th Fl New York NY 10022 United States | 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, setter and beneficiaries, etc.: Richard Kahn is 100% owner and signor of this entity. Please indicate how ownership of the legal entity is reflected: Richard Kahn 50% owner Harry Beller 50% owner | ||||
| 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): Richard Kahn is 100% owner and signor of this entity. | ||||
| To 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)? Yes No | ||||
| Describe Nature of Entity's Primary Business and Investment Activities | ||||
| Nature of the business: Accounting firm | ||||
| Countries where business is transacted: USA | ||||
| Number of employees: 2 | ||||
| 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): Rich is an in-house accountant for Jeffrey Epstein. His started this company with Harry Beller who retired. The company assets come from the fees he charges for this service. | ||||
| Estimated gross receipts p.a.($): 400,000.00 | ||||
| Estimated net profit p.a. ($): 300,000.00 | ||||
| Estimated investable assets ($): <$1 MM | ||||
| Potential Amount to be invested with PWM ($): 200,000.00 | ||||
| Other Known Financial Institutions: | ||||
| Institution: | DB | Country: | USA | Est. Assets Under Mgt: 200,000.00 |
| Institution: | Country: | Est. Assets Under Mgt: | ||
| Institution: | Country: | Est. Assets Under Mgt: | ||
| Relationship Name | EPSTEIN, JEFFREY RELATIONSHIP | |||||||
| Risk Rating Comments: | ||||||||
| Booking Center | NY | NY/Offshore | Offshore | Moderate Risk | High Risk | Yeonsun Chung | ||
| (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 | |
| PCR checks complete | Yes | No | |
| OFAC checks complete | Yes | No | |
| BIS searches complete (Lexis/Nexis, Factiva, Reuters, Dow Jones, D&B) | Yes | No | |
| Denial Orders checks complete | Yes | No | |
| Martindale-Hubbell searched (Lawyers/Law Firms only) | Yes | No | |
| Please summarize any negative results from the database searches indicated above: | DARREN K. INDYKE: No negative Media No court cases | ||
| NEW YORK STRATEGY GROUP, LLC: No negative media No court cases | |||
| DARREN K. INDYKE PLLC: No negative media No court cases | |||
| HRRK ASOCIATES INC: No negative media No court cases | |||
| D. | RICHARD KAHN: Approved KYC #01082293 AML Clearance attached to this KYC Not barred from NYSE Arca and he was cleared twice as seen in the attachments | ||
| HARRY BELLER: Negative Media: Not our client. All negative media pertains to an environmental microbiologist. Our client is an accountant Court Cases #11; Dispoed in 1987 All other cases are not our client. The other court cases refer to a Dr. Harry Beller. Our client is an accountant | |||
| JEFFREY EPSTEIN INSURANCE TRUST: No negative media No court cases | |||
| JEFFREY EPSTEIN: Previously KYCd and approved in: 01082293 and 01121718 | |||
| E. | To the best of your knowledge, has the client ever been convicted of a criminal offense? | 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 litigation against Deutsche Bank AG or any of its subsidiaries? (If Yes, provide detail below and contact Quality Mgt. (UK/MN/TM) or the Regulatory Control Group and notify Compliance immediately) | Yes | No |
| G. | Yes | No | |
| 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)? | |
| H. | Does the client or related party have any financial or other association/ interactions within high risk countries?☐Yes ☑No |
| 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?☐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 | |
| M. Case Comments | ||
| Created By | Date | Comments |
| Cynthia Rodriguez | 7/17/117 1:05 PM | Dated resolution attached |
| Kshitj Golani | 7/18/117 1:01 PM | HBRK Associates Inc and Darren K Indyke PLLC(accountholders) have been clients of DB since 2013.Below are the reasons why we are comfortable with approving this update/high risk review•Information and supporting documents required by our AML Policy were provided and reviewed;and as a result,we have an understanding of the structure of the account holders,their purpose,the purpose of the accounts and expected transaction activity•The account holders' source of wealth and source of funds were sufficiently detailed and appears plausible•The account holders' source of wealth is via the company's operations,which is accounting firm/law firm•Our review did not identify any red flags relating to fraudulent ownership hence we believe the true ownership of the account holder was identified•We performed due diligence searches on all key parties including the client,UBOs and authorized signatories and did not find the names searched to be on any sanctions lists. |
| Cynthia Rodriguez | 7/17/117 1:25 PM | purpose of the accounts and current activities have been reflected on the KYC |
| Cynthia Rodriguez | 7/17/117 1:05 PM | * HBRK |
| Cynthia Rodriguez | 7/17/117 1:04 PM | KBRK Incorporation docs attached to reflect ownership. |
| Cynthia Rodriguez | 7/17/117 1:23 PM | Stew Oldfield reached out to Rich Kahn and Darren Indyke on 7/7/2017 to confirm material changes to the accounts |
| Cynthia Rodriguez | 7/18/117 11:41 AM | tax ownership document attached showing rich kahn as sole owner. |
| ONSHORE APPROVALS | |||
| Client Facing Professional(CFP): | stewart oldfield | (Signature) stewart oldfield | 7/13/2017 |
| Office Director/Business Head: | Andrew F Gallivan | (Signature) Andrew F Gallivan | 7/14/2017 |
| Regional Office Director: | (Signature) | ||
| AML Business Risk: | (Signature) | ||
| AML Compliance: | (Signature) | ||
| Kshitij Golani | Kshitij Golani | 7/18/2017 | |
| Yoonsun Chung | Yoonsun Chung | 7/18/2017 | |
| 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) | ||