KYC Print Page 1 of 41 DB PWM GLOBAL KYC/NCA: PART A # 1. Relationship Details **Relationship Name:** SOUTHERN FINANCIAL RELATIONSHIP:00000483290 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: *** 2018 Periodic Review **** **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 3/7/17 to have a new act opened under this relationship. Last Approved KYC # - 1790724; Butterfly Trust - 1804531; Neptune, LLC - 1790739. **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 | | 12/13/2013 | | 2 | | 1/24/2014 | | 3 | | 10/18/2013 | Who is the primary contact person for the RM? (Note: This person needs to have signatory rights and/or information right for the accounts.): | Account Name / Number | Preferred method of contact (indicate phone no., fax no., e-mail address, etc.): | | :--- | :--- | CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. (e) DB-SDNY-0000376 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... USAO 001339 7/11/2019 EFTA_00019249 EFTA00168996 KYC Print Page 2 of 41 One sheet must be established for each account to be opened
| 2. Account Ownership Summary | ||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Account Name: | & | 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)? This is a checking account for Individuals. They use the funds for daily expenses. | ||||||||||||||
| Indicate from where the assets are expected to arrive? ☑ DB Group: Same Booking Center (indicate account number): Existing ☐ 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)? 2-6/month; $1 - $2000 | ||||||||||||||
| What is the expected volume of assets and currency for the account approx. 90 days after opening? | ||||||||||||||
| What is the expected volume of assets and currency for the account approx. one year after opening? | ||||||||||||||
| 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 | □ | ✓ | ✓ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ | ||
| 2 | □ | ✓ | ✓ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ | ||
| □ | □ | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ | ||||
| 13 | □ | □ | Darren K. Indyke | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ | ||
| 14 | □ | ✓ | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ | |||
| 15 | □ | □ | Richard D. Kahn | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ | ||
| 16 | □ | ✓ | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | □ |
| 2. Account Ownership Summary | ||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Account Name: | Neptune LLC - 42953424 - DDA | Acct. Number ( if available): | 42953424 | |||||||||||
| 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)? This is a checking account to pay for all expenses (i.e. electric, maintenance, cable, etc.) on Epstein's NYC home. | ||||||||||||||
| Indicate from where the assets are expected to arrive? | ||||||||||||||
| ☑ DB Group: Same Booking Center (indicate account number): Existing ☐ 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)?: 15-20/month; $10-$10000 | ||||||||||||||
| What is the expected volume of assets and currency for the account approx. 90 days after opening? What is the expected volume of assets and currency for the account approx. one year after opening? 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 checks leaves 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 | Settor of Trust / Founder Foundation | Ultimate Beneficiary of Owner | Signatory or Full POA | Limited POA | Financial Intermediary (FIM) | Significant Shareholder (>=25%) No/NYC entity (indicate ownership %) | Legal Representative | Grantor/Settion Donor | Founding Donor | Other (please describe other roles and/or indicate relationship between parties) |
| 1 | □ | ✓ | Jeffrey E. Epstein | □ | □ | ✓ | ✓ | □ | □ | □ | □ | □ | Sole Member of Neptune LLC; | |
| 2 | □ | □ | Harry Beller | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | ||
| 3 | □ | □ | Darren K. Indyke | □ | □ | □ | ✓ | □ | □ | □ | □ | □ | ||
| 4 | ✓ | ✓ | Neptune, LLC | ✓ | □ | □ | □ | □ | □ | □ | □ | □ | ||
| 5 | □ | □ | Richard D. Kahn | □ | □ | □ | □ | □ | □ | □ | □ | □ | Manager of Neptune LLC; | |
| Institution: | Country: | Est. Assets Under Mgt: | |||
| Please indicate the family situation of the individual (marital status, other family members, etc.): Married to Karyna Shuliak | |||||
| 3A. Individual Details (for all parties) | ||||||
|---|---|---|---|---|---|---|
| Individual's Name: | Jeffrey E. Epstein - 00000483289 | Date of Birth: | 1/20/1953 | |||
| Country of Residence: | Virgin Islands, U.S. | Country of Citizenship: | United States | |||
| Address of primary residence: | Little Saint James Saint Thomas 00802 Virgin Islands, U.S. | 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 Trust Company Inc | Position/Title/Rank: | President | |||
| Address of employer: | 6100 Red Hook Quarter B3 St. Thomas Virgin Islands, U.S. 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) | ||||||
| Is the individual a Politically Exposed Person (PEP)?(if Yes, describe) Connection with Prince Andrew and Bill Clinton | ||||||
| To the best of your knowledge, is the individual related to an employee of the DB group?(if Family or Friendship, describe) N/A | ||||||
| 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) N/A | ||||||
| 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: | |
| Stewart Oldfield | ✓ | □ | □ | 28/2017 | ||
| □ | □ | □ | ||||
| □ | □ | □ | ||||
| 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? | United States | |
| Primary industry of source of Wealth/Source of Funds? | High Risk Financial Institutions | |
| 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 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.) Jeffrey Edward Epstein(born January 20, 1953) is an American financier and registered sex offender in the United States. He worked at Bear Stearns early in his career and then formed his own firm.J. Epstein & Co.He lives in the US Virgin Islands.Epstein taught calculus and physics at the Dalton School in Manhattan from 1973 to 1975.Among his students was a son of Alan C. Greenberg, chairman of Bear Stearns.In 1976, Epstein started work as an options trader at Bear Stearns where he worked in the special products division, advising high-net-worth clients on tax strategies.Providing successful in his financial career, in 1980 Epstein became a partner at Bear Stearns.In 1982, Epstein founded his own financial management firm.J. Epstein & Co., managing the assets of clients with more than $1 billion in net worth.In 1987, Leslie Wexner, founder and chairman of Ohio-based The Limited chain of women's clothing stores, became a well-known client.Wexner acquired Abercrombie & Fitch the following year.In 1992 he converted a private school on the Upper East Side into an enormous residence.Epstein later bought that property, in the wealthiest part of Manhattan.In 1996, Epstein changed the name of his firm to the Financial Trust Company and, for tax advantages, based it on the island of St. Thomas in the U.S.Virgin Islands.In 2003, Epstein bid to acquire New York magazine.Other bidders were advertising executive Donny Deutsch, investor Nelson Peltz, media mogul and publisher Mortimer Zuckerman, who had the New York Daily News, and film producer Harvey Weinstein.They were ultimately outbid by Bruce Wasserstein, a longtime Wall Street Investor, who paid $55 million.In 2004, Epstein and Zuckerman committed up to $25 million to finance Radar a celebrity and pop culture magazine founded by Maer Roshan.Epstein and Zuckerman were equal partners in the venture.Roshan, as its editor-in-chief, retained a small ownership stake. | ||
| Please indicate how ownership of the legal entity is reflected: Addition of Beneficiaries attached | ||
| 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): This is an irrevocable trust set up by Jeffrey Epstein as the grantor.The beneficiaries for the trust are being updated by the current trustees.The trustees are Harry Beller and Erika Kellerhals.The beneficiaries are:Darren IndykeRichard Kahn | ||
| 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)?N/A | Yes☐No✓ | |
| Describe Nature of Entity's Primary Business and Investment Activities | ||
| Nature of the business: | Trust account | |
| Countries where business is transacted: | Virgin Islands,U.S. | |
| Number of employees: | N/A | |
| 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? | United States | |||||
| Primary industry of source of Wealth/Source of Funds? | High Risk Financial Institutions | |||||
| Provide Evidence of Corporate Assets(e.g. balance sheet or equivalent summary of assets/liabilities):Trust account with Jeffrey Epstein as Grantor.Initial $100 given to the account to fund.The funds for this trust account come from investments made by Jeffrey Epstein.His wealth profile is filled out. | ||||||
| Estimated gross receipts p.a.($): | 4,500,000.00 | |||||
| Estimated net profit p.a.($): | 4,500,000.00 | |||||
| Estimated investable assets($): | $5MM-10MM | |||||
| Potential Amount to be invested with PWM($): | 700,000.00 | |||||
| Other Known Financial Institutions: | ||||||
| Institution: | Country: | Est. Assets Under Mgt: | ||||
| Institution: | Country: | Est. Assets Under Mgt: | ||||
| Institution: | Country: | Est. Assets Under Mgt: | ||||
| 3C. Legal Entity Details(For all Legal Entities) | |||
| Legal Entity Name: | Neptune, LLC-00000487264 | ||
| 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: | United States | Date of incorporation/ registration: | 12/21/2011 |
| Volcker Status: | Identified on Customer Profile | Volcker Flag: | No | |
| Address(city, street, post code): | 6100 Red Hook, Quarter B3 St, Thomas 00802 Virgin Islands, U.S. | 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,settior and beneficiaries,etc.:Single member LLC. Jeffrey Epstein is the sole member.The signors on this account are Jeffrey Epstein,Harry Beller,Darren Indyke.Richard Kahn is the manager. | ||||
| Please indicate how ownership of the legal entity is reflected:Operating 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):Single member LLC. Jeffrey Epstein is the sole member.The signors on this account are Jeffrey Epstein,Harry Beller,and Darren Indyke.Richard Kahn is the manager. | ||||
| 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)?N/A | Yes No | |||
| 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: | United States | |||
| Number of employees: | 3 | |||
| 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? | United States | |||||
| Primary industry of source of Wealth/Source of Funds? | High Risk Financial Institutions | |||||
| Provide Evidence of Corporate Assets(e.g. balance sheet or equivalent summary of assets/liabilities):This LLC is funded by contributions made by Jeffrey Epstein. | ||||||
| Estimated gross receipts p.a.( $ ): | 1,000,000.00 | |||||
| Estimated net profit p.a. ( $ ): | 1,000,000.00 | |||||
| Estimated investable assets ( $ ): | <$1 MM | |||||
| Potential Amount to be invested with PWM ( $ ): | ||||||
| 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 | ||
| (Compliance Signature) | |||||||
| DB Employee | DB Managed PIC | DB is Trustee/Co-Trustee | Bearer Shares | ||||
| Erika Kallehals: - No negative media - No court cases | |
| - No negative media - Court case is immaterial since she is not a defendant nor plaintiff. Her name is just mentioned as miscellaneous. Case is closed as well. | |
| Neptune LLC: - No negative media - No court cases | |
| - No negative media - No court cases | |
| - No negative media - No court cases | |
| - No negative media - No court cases | |
| - No negative media - No court cases | |
| - No negative media - No court cases | |
| Southern Trust Company Inc: - No negative media - No court cases | |
| 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 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 details below and contact Quality Mgt. (Laden/Intf) 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 (OPAC)? ☑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? ☑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 |
| Kshitij Golani | 9/25/118 10:04 AM | This KYC serves as a high risk update for the below listed clients(together"accountholders")- 1. && 2. Butterfly Trust 3. Neptune LLC 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 account holders,their purpose,the purpose of the accounts and expected transaction activity. • There are a few risk factors associated with the account holders- SOW:The UBO(Jeffrey Epstein)是the founder of Southern Trust Company Inc,which manages client's assets.SOW verification was obtained.In addition, Negative 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 obtained. • Our review did 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 not find the names searched to be on any sanctions lists. |
| Mayur Rathod | 9/3/118 3:17 AM | No material changes confirmation"email" attached in the case. |
| ONSHORE APPROVALS | |||
| Client Facing Professional(CFP): | Stewart Oldfield | (Signature) Stewart Oldfield | 9/5/2018 |
| Office Director/Business Head: | Steven Mattus | (Signature) Steven Mattus | 9/6/2018 |
| Regional Office Director: | (Signature) | ||
| AML Business Risk: | (Signature) | ||
| AML Compliance: | Kshitij Golani | (Signature) Kshitij Golani | 9/25/2018 |
| 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) | ||