Deutsche Bank KYC review of Jeffrey Epstein's HBRK Associates and Indyke accounts, 2017

KYC Print¶

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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
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¶

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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	□	□	□	✓	□	□		□	□	□	□

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000247¶

USAO 001210 7/11/2019¶

https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N3000000D9Di&e…¶

EFTA_00019120¶

EFTA00168867¶

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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	✓	☐	☐	☐	☐	☐	☐	☐	☐	☐

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000248¶

https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e…¶

USAO 001211 7/11/2019¶

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This is a simple Markdown document with no headings, paragraphs, or tables. It contains just the text “EFTA_00019121”.¶

EFTA00168868¶

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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:	Darren K. Indyke
Country of Residence:	USA
Address of primary residence:
Profession/Occupation:	Lawyer
Current Employer:	Southern Financial LLC
Address of employer:	575 Lexington Ave, 4th Fl Livingston NY United States 10022

Date of Birth:¶

Country of Citizenship: USA¶

Has client resided outside of his/her country of nationality for 5 years or more?¶

Tax ID / SSN:¶

Position/Title/Rank:¶

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)¶

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:¶

Bank Officer Name(s) | Bank Office | Client Private domicile | Client Place of Business | Other Location (specify): | Date:¶

☐ | ☐ | ☐ | ☐ | | |¶

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000249¶

USAO 001212¶

7/11/2019¶

https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e…¶

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EFTA00168869¶

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

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000250¶

https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e…¶

USAO 001213 7/11/2019¶

EFTA_00019123¶

EFTA00168870¶

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

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

3A. Individual Details (for all parties)¶

Individual’s Name:	Richard D. Kahn	Date of Birth:
Country of Residence:	USA	Country of Citizenship: USA
Address of primary residence:		Has client needed of higher country of nationality for 5 years or more?
Profession/Occupation:	Accountant	Tax ID / SSN:
Current Employer:	HBRK Associates, Inc	Position/Title/Rank:
Address of employer:	575 Lexington Ave, 4th Fl New York NY United States 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:¶

Bank Officer Name(s)	Bank Office:	Client Private domicile:	Client Place of Business:	Other Location (specify):	Date:
	□	□	□
	□	□	□
	□	□	□

☐ Wealth Details for this individual are not filled in, because they are the same as for the following person:¶

3B. Wealth Details (Only for parties requiring source of wealth description as indicated in Section 2)¶

Nature of the Individual’s Business: Accountant¶

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., trusts, how did settler 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.) Rich Kahn has been an in-house accountant for Jeffrey Epstein for over 10 years. He began HBRK with another in house accountant Harry Beller, Mr. Beller is now retired and Rich has taken over ownership of this entity. Assets come from the rates he charges for his accounting services.¶

Estimated Annual Income($): 116,000.00 Estimated amount of investable assets($): <$1 MM¶

Estimated Net Worth($): <$1 MM Amount of assets planned to invest with PWM($):¶

Other Known Financial Institutions:¶

Institution: DB Country: USA Est. Assets Under Mgt:¶

Institution: Country: Est. Assets Under Mgt:¶

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000251¶

USAO 001214¶

7/11/2019¶

https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e..¶

EFTA_00019124¶

EFTA00168871¶

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Institution:		Country:		Est. Assets Under Mgt:
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:	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:

One sheet must be established for EACH LEGAL ENTITY in Section 2. Account Summary¶

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000252¶

https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e… 7/11/201¶

EFTA_00019125¶

EFTA00168872¶

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3C. Legal Entity Details (For all Legal Entities)¶

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:

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000253¶

USAO 001216 7/11/2019¶

https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e… 7/1¶

EFTA_00019126¶

EFTA00168873¶

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

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

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000254¶

USAO 001217¶

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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

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000255¶

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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)

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000256¶

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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¶

CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e)¶

DB-SDNY-0000257¶

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