KYC Print Page 1 of 10 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: | SOUTHERN FINANCIAL 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: Initial funding must take place by 02/13/2018 in order to purchase assets for the trust. | | | | 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 reached out to Stew Oldfield on 2/02/2018 to open a new deposit account for his annuity trust. Initial funding must take place by 02/13/2018 in order to purchase assets for the trust. | | | | 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 | The 2017 Caterpillar Trust - Deposit | 2/13/2018 | | Who is the primary contact person for the RM? (Note: This person needs to have signatory rights and/or information right for the accounts.): | Groff, Lesley | Preferred method of contact (indicate phone no., fax no., e-mail address, etc.): | CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0000300 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... USAO 001263 7/11/2019 EFTA_00019173 EFTA00168920 KYC Print Page 2 of 10 One sheet must be established for each account to be opened
| 2. Account Ownership Summary | ||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Account Name: | The 2017 Caterpillar Trust - 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)? the purpose of this account is to hold the member interest in IGO Company LLC | ||||||||||||||
| 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)? less than 2 distributions on an annual basis between $0 and $100k | ||||||||||||||
| What is the expected volume of assets and currency for the account approx. 90 days after opening? 300000CurrencyUSD | ||||||||||||||
| What is the expected volume of assets and currency for the account approx. one year after opening? 300000CurrencyUSD | ||||||||||||||
| Does/will the client have Assets Under Management (AuM) within DB under Eur. 3M? ☐ Yes ☑ No | ||||||||||||||
| Please list all parties related to the account. For each party: • Check if a source of wealth description is required for the party. • Check the appropriate box to describe the relationship of the party to this account (> 1 can be selected). If none of the check boxes apply, describe the party relation to the account in the “Other” column. • Always describe the relationship between the parties in the last column. • Please drill down to the ultimate/underlying Beneficial Owner(s). | ||||||||||||||
| Legal Entity or Source of Wealth required | Description of Wealth required | Parties related to this account | Account Holder | PIC Owner | Settler of Trust / Founder Foundation | Ultimate Beneficial Owner | Signatory for Full POA | Limited POA | Financial Intermediary (FIM) | Significant Shareholder (> 52%) Non-PIC entity (indicate ownership %) | Legal Representative (≥ 52%) Non-PIC entity (indicate ownership %) | Grantor/Settler | Founding Donor | Other (please describe other roles and/or indicate relationship between parties) |
| 1 | ✓ | ✓ | The 2017 Caterpillar Trust | ✓ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ | □ |
| 2 | □ | ✓ | Jeffrey E Epstein | □ | □ | ✓ | ✓ | □ | □ | □ | □ | □ | □ | Beneficiary; Grantor and Beneficiary of The 2017 Caterpillar Trust; Grantor of the 2013 Butterfly Trust; |
| 3 | □ | □ | Wallace Daphne | □ | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | Trustee;; trustee; |
| 4 | □ | □ | Groff, Lesley | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ | trustee;; trustee; |
| Estimated Annual Income($): | 10,000,000.00 | Estimated amount of investable assets($): | $50 MM-100 MM | ||||||
| Estimated Net Worth($): | $500 MM+ | Amount of assets planned to invest with PWM($): | |||||||
| Other Known Financial Institutions: | |||||||||
| Institution: | Country: | Est. Assets Under Mgt: | |||||||
| Institution: | Country: | Est. Assets Under Mgt: | |||||||
| Institution: | Country: | Est. Assets Under Mgt: | |||||||
| 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: | The 2017 Caterpillar Trust | |||
| Type of Entity: | Foundation/AssociationTrustCompanyEstatePartnership | Purpose of Entity: | Private InvestmentPhilanthropic/CharitableCommercial | |
| Type of Entity Other(specify): | Purpose of Entity Other(specify): | |||
| Country of incorporation/registration: | Virgin Islands, U.S. | Date of Incorporation/registration:1/3/2017 | ||
| Volcker Status: | Determination Required | Volcker Flag:No | ||
| Address(city, street, post code): | 6100 Red Hook Quarter B3, St Thomas 00802 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, settlor and beneficiaries, etc.This is a grantor retained annuity trust that holds membership interest in IGO Company LLC. This trust will terminate two years from the date of initial funding and annual annuity distributions will be paid to the grantor only. Upon termination, the membership interest will then transfer to the 2013 Butterfly Trust.Grantor: Jeffrey EpsteinTrustee: Lesley Groff and Daphne WallaceBeneficiaries: Jeffrey Epstein and The 2013 Butterfly Trust(upon termination of trust) | ||||
| Please indicate how ownership of the legal entity is reflected: trust agreement | ||||
| 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): Grantor: Jeffrey EpsteinTrustee: Lesley Groff and Daphne WallaceBeneficiaries: Jeffrey Epstein and The 2013 Butterfly Trust(upon termination of trust) | ||||
| 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: | This is a grantor retained annuity trust that holds membership interest in IGO Company LLC. | |||
| Countries where business is transacted: | usa | |||
| Number of employees: | 0 | |||
| 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):The source of wealth for this trust derives from Jeffrey Epstein.Please revert to his source of wealth for more details. | |||||
| Estimated gross receipts p.a($): | 1,000,000.00 | ||||
| Estimated net profit p.a($): | 1,000,000.00 | ||||
| Estimated investable assets($): | $1MM-2MM | ||||
| Potential Amount to be invested with PWM($): | 1,000,000.00 | ||||
| Other Known Financial Institutions: | |||||
| Institution: | Country: | Est. Assets Under Mgt: | |||
| Institution: | Country: | Est. Assets Under Mgt: | |||
| Institution: | Country: | Est. Assets Under Mgt: | |||
| Relationship Name | SOUTHERN FINANCIAL RELATIONSHIP | ||||||
| Risk Rating Comments: | |||||||
| Booking Center | NY | NY/Offshore | Offshore | Moderate Risk | High Risk | Yoonsun Chung | |
| (Compliance Signature) | |||||||
| DB Employee | DB Managed PIC | DB is Trustee/Co-Trustee | Bearer Shares | ||||
| (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/Nexis, Factiva, Reuters, Dow Jones, D&B) | ☑ 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 | |
| D. | Please summarize any negative results from the database searches indicated above: | |||
| 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 in the customer threatening litigation against Deutsche Bank AG or any of its subsidiaries? (If Yes, provide details below and contact Quality Mgt. (LukAm/Tntl) 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/contents of the non-English Documentation: | |||
| L. | Special Risk Factors | |||
| Does the account have Nexus to Special Risk Counties? ☑ 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 |
| Yoonsun Chung | 3/16/118 10:52 AM | The client Trust is registered in US VI, not USA. |
| Matthew-J Purcell | 2/13/118 11:13 AM | This KYC serves as a high risk review for the new client The 2017 Caterpillar Trust (referred as “accountholder”)Below are the reasons why we are comfortable with approving this KYC: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 accountholders, their purpose, the purpose of the accounts and expected transaction activityThere are a few risk factors associated with the accountholder-SOW:The UBO (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages clients assets.SOW verification was obtainedNegative Media & PEP:There is some negative media against Mr Epstein and he is also maintains a close relationship with Bill Clinton and Prince Andrew.Please see risk calculator for more information.Appropriate approval was obtainedOur review did not identify any red flags and thus there was no need to escalate this case furtherWe performed due diligence searches on all parties and did not find the names searched to be on any sanctions lists |
| Cynthia Rodriguez | 2/8/118 10:59 AM | Please Note:The 2013 Butterfly trust is listed as a beneficiary only when the 2017 Caterpillar Trust terminates.Since this beneficiary does not receive the annual annuity payments, it was not added as a party.However,I have attached the trust agreement and list of beneficiaries for this trust as support. |
| ONSHORE APPROVALS | |||
| Client Facing Professional(CFP): | stewart oldfield | (Signature) stewart oldfield | 2/8/2018 |
| Office Director/Business Head: | Andrew F Gallivan | (Signature) Andrew F Gallivan | 2/8/2018 |
| Regional Office Director: | (Signature) | ||
| AML Business Risk: | (Signature) | ||
| AML Compliance: | (Signature) | ||
| Matthew-J Purcell | Matthew-J Purcell | 2/13/2018 | |
| Yoonsun Chung | Yoonsun Chung | 2/13/2018 | |
| 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) | ||