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: | 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 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 JPMorgan. Over the course of a few meetings Paul was able to get Jeffrey to bring some of his funds over to JPMorgan | | | | 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 | Southern Financial, LLC | 8/19/2013 | | 2 | Southern Financial, LLC | 8/19/2013 | | 3 | Southern Trust Company, Inc. | 8/19/2013 | | 4 | Southern Trust Company, Inc. | 8/19/2013 | Who is the primary contact person for the RM? (Note: This person needs to have signatory rights and/or information right for the accounts.): https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e) 7/18/2019 USAO 001439 DB-SDNY-0000479 EFTA_00019349 EFTA00169096 KYC Print Page 2 of 12 One sheet must be established for each account to be opened
2. Account Ownership Summary
Account Name:Southern Financial, LLCAcct. 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 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): JP Morgan, 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 2 inflows & outflows per month ranging from $1000 to $10,000.
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?
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2. Account Ownership Summary
Account Name:Southern Financial, LLCAcct. 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 to hold funds 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): 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 10 inflows and 10 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?50,000CurrencyUSD
What is the expected volume of assets and currency for the account approx. one year after opening?100,000CurrencyUSD
Does/will the client have Assets Under Management (AuM) within DB under Eur. 3M?
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 EntityDescription of Wealth RequiredParties related to this accountAccount HolderPIC OwnerSetter of Trust / Founder FoundationUltimate Beneficiator Full POALimited POAFinancial Intermediary (FIM)Significant Shareholder (>=25%) Non-PIC entity (Indicate ownership %)Legal RepresentativeGrantor/SettterFounding DonorOther please describe other roles joint or indicate relationship between parties)
1□✓Jeffrey Epstein□□□□✓□□□□□
2✓✓Southern Financial L.C.✓□□□□□□□□
3✓✓Southern Trust Company, Inc.□□□□□□100□□□Southern Trust is the sole member of Southern Financial and Jeffrey Epstein is the sole shareholder of Southern Trust;
https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e) 7/18/2019 USAO 001441 DB-SDNY-000048 | EFTA_00019351 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00169098 KYC Print Page 4 of 12 # 2. Account Ownership Summary | Account Name: | Southern Trust Company, Inc. | 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. To hold funds for 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): 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 10 inflows and 10 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? 100,000 What is the expected volume of assets and currency for the account approx. one year after opening? 100,000 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 | Settlor of Trust / Founder of Foundation | Signator 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. □ ☑ Jeffrey Epstein | □ | □ | □ | □ | □ | □ | | | □ | □ | □ | □ | Sole shareholder of Southern Trust; 2. ☑ ☑ Southern Trust Company, Inc. | ☑ | □ | □ | □ | □ | □ | | | □ | □ | □ | □ | □ | https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e) 7/18/2019 USACO 001442 DB-SDNY-0000482 EFTA_00019352 EFTA00169099 KYC Print Page 5 of 12 # 2. Account Ownership Summary | Account Name: | Southern Trust Company, Inc. | 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 account. To hold funds 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): JPMorgan, NY - □ 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 2 inflows & 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? 50,000 Currency USD What is the expected volume of assets and currency for the account approx. one year after opening? 150,000 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(5). | Legal Entity | Description of Source of Wealth required | Parties related to this account | Account Holder | PIC Owner | Settlor 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/Settler | Founding Donor | Other (please describe other roles and/or indicate relationship between parties) | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | 1. □ ✓ Jeffrey Epstein | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | 2. ✓ ✓ Southern Trust Company, Inc. | ✓ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | □ ✓ | https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... USAO 001443 CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-00004 EFTA_00019353 EFTA00169100 KYC Print Page 6 of 12 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: | Jeffrey Epstein | | :--- | :--- | | Country of Residence: | USVI | | Address of primary residence: | Litte Saint James Saint Thomas 00802 US Virgin Islands | | Profession/Occupation: | Self Employed | | Current Employer: | Southern Financial LLC | | Address of employer: | 6100 Red Hook Quarter B3 St. Thomas USVI 00802 | Do the person work as senior executive of a DB-recognized regulated entity in the financial industry? or an entity listed on a DB-recognized 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: | | :--- | :--- | :--- | :--- | :--- | :--- | | Paul Morris | □ | □ | □ | □ | 4/3/2013 | | | □ | □ | □ | □ | | | | □ | □ | □ | □ | | ☐ 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: Private investments Primary Country of source of wealth/source of Funds? Primary Industry of source of Wealth/Source of Funds? Summary 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! Epstein began his financial career in 1979 as an options trader at Bear Stearns and became a partner n 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 1994, 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 Wheeler. His wealth has come from his days at Bear Stearns and his financial management firms Estimated Annual Income($): 10,000,000.00 Estimated Net Worth($): $100 MM - 500 MM Amount of assets planned to invest with PWM($): 10,000.00 Other Known Financial Institutions: Institution: JPMorgan Country: USA Est. Assets Under Mgt: 20,000,000.00 Institution: Country: Est. Assets Under Mgt: https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e) 7/18/2019 USAO 001444 DB-SDNY-000048 EFTA_00019354 EFTA00169101 KYC Print Page 7 of 12
Institution:Country:Est. Assets Under Mgt:
Please indicate the family situation of the individual (marital status, other family members, etc.): Single
3C. Legal Entity Details(For all Legal Entities)
Legal Entity Name:Southern Financial LLC
Type of Entity:Foundation/Association Trust Company Estate PartnershipPurpose of Entity:Private Investment Philanthropic/Charitable Commercial
Type of Entity Other(specify):Purpose of Entity Other(specify):
Country of incorporation/registration:US Virgin IslandsDate of incorporation/ registration:2/25/2013
Volcker Status:Volcker Flag:
Address(city, street, post code):6100 Red Hook Quarter B3 St Thomas 00802 US Virgin IslandsU.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.: Southern Trust Company Inc is the sole member of Southern Financial LLC. Jeffrey Epstein is the sole shareholder of Southern Trust Company IncPlease indicate how ownership of the legal entity is reflected: Southern Trust Company Inc is the sole member of Southern Financial LLC. Jeffrey Epstein is the sole shareholder of Southern Trust Company IncSpecial 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): Southern Trust Company Inc is the sole member of Southern Financial LLC. Jeffrey Epstein is the sole shareholder of Southern Trust Company Inc
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:This business is funded by Jeffrey Epstein's wealth. This company was formed to hold Mr. Epstein's personal wealth and invest in different ventures. This company invests in real estate, equities, commodities, etc and gets its revenue from the gains it makes in these investments. It is a company formed to invest the assets of Mr. Epstein
Countries where business is transacted:US Virgin Islands
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?
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 initial funding in February 2013 was $1,000 from the sole shareholder of the sole managing member(Jeffrey Epstein)。
Estimated gross receipts p.a.($):2,000,000.00
Estimated net profit p.a.($):1,500,000.00
Estimated investable assets($):<$1MM
Potential Amount to be invested with PWM($):300,000.00
Other Known Financial Institutions:
Institution:JPMorganCountry:USAEst. Assets Under Mgt:1,000,000.00
Institution:Country:Est. Assets Under Mgt:
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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:Southern Trust Company, Inc.
Type of Entity:Foundation/Association TrustCompanyEstatePartnershipPurpose of Entity:Private InvestmentPhillanthropic/CharitableCommercial
Type of Entity Other(specify):Purpose of EntityOther(specify):
Country of incorporation/registration:US Virgin IslandsDate of incorporation/registration:11/18/2011
Volcker Status:Volcker Flag:
Address(city, street, postcode):6100 Red Hook Quarter B3 St Thomas 00802 US Virgin IslandsU.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.
Please indicate how ownership of the legal entity is reflected:Jeffrey Epstein is sole managing 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):Jeffrey Epstein is sole managing member
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)^{2}$
Describe Nature of Entity's Primary Business and Investment Activities
Nature of the business:Consulting Services relying on Financial and Biomedical algorithms.Southern Trust is a private consulting company that invests the assets of their clients and gets their revenue from the return of these investments.Southern Trust invests in different portfolios catered to their clients and makes their revenue based on the returns and the fees associated with managing their clients assets
Countries where business is transacted:US Virgin Islands
Number of employees:4
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):Consult and invest client funds and gain revenue based on fees and returns
Estimated gross receipts p.a.( $ ):2,000,000.00
Estimated net profit p.a.( $ ):1,500,000.00
Estimated investable assets( $ ):$2MM-5MM
Potential Amount to be invested with PWM( $ ):300,000.00
Other Known Financial Institutions:
Institution:JPMorganCountry:USAEst. Assets Under Mgt:2,000,000.00
Institution:Country:Est. Assets Under Mgt:
Institution:Country:Est. Assets Under Mgt:
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Relationship NameEPSTEIN, JEFFREY RELATIONSHIP
Risk Rating Comments:
Booking CenterNYNY/OffshoreOffshoreModerate RiskHigh Risk
(Compliance Signature)
DB EmployeeDB Managed PICDB is Trustee/Co-TrusteeBearer Shares
(Compliance Signature)
□ DB Employee□ DB Managed PIC□ DB is Trustee/Co-Trustee□ Bearer Shares
4. Attachments
A.Type of Photo ID ProvidedDrivers LicensePassportNational/State ID
B.Checklist of names (individuals and/or entities) that were submitted for database searches is attachedYesNo
C.Please indicate the results of the database searches performed
RDC searches completeYesNonegative results foundYes
PCR checks completeYesNonegative results foundYes
OFAC checks completeYesNonegative results foundYes
BIS searches complete (Lexis/Nexis, Factiva, Reuters, Dow Jones, D&B)YesNonegative results foundYes
Denial Orders checks completeYesNonegative results foundYes
Martindale-Hubbell searched (Lawyers/Law Firms only)YesNonegative results foundYes
Please summarize any negative results from the database searches indicated above: JEFFREY EPSTEIN: RDC Alert #1 — Cleared & APPROVED by Chip Packard, AML Compliance, and Pat Harris PCR Alert #1/2 — Not our client All Cases Closed
SOUTHERN FINANCIAL LLC: No negative media No court cases
SOUTHERN TRUST INC: No negative media Court Case — Not our client.
FINANCIAL INFORMATICS INC: No negative media No court cases
J. Epstein & Co. All Negative Media is our client. He has been cleared of posing a reputational risk as shown by the AML Clearance attached Court Cases have been closed
FINANCIAL TRUST & CO. RDC/PCR alert is associated with Southern Financial, the company it merged into. This alert has been cleared by Compliance and is attached Court Cases are closed
E. To the best of your knowledge, has the client ever convicted of a criminal offense?YesNo
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 details below and contact Quality Mgt. (LAutn/Int) or the Regulatory Control Group and notify Compliance immediately)YesNo
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)?YesNo
H. Does the client or related party have any financial or other association/ interactions within high risk countries?YesNo
I. Corporate Documentation Attached (Legal Entities Only)YesNoNot Applicable
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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
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M. Case Comments
No records to display.
ONSHORE APPROVALS
Client Facing Professional(CFP):Paul Morris(Signature) Paul Morris7/17/2013
Office Director/Business Head:Brian M. Biggar(Signature) Brian M. Biggar7/18/2013
Regional Office Director:(Signature)
AML Business Risk:Armen Brash(Signature) Armen Brash8/20/2013
AML Compliance:Janice Franklin(Signature) Janice Franklin8/21/2013
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 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e) EFTA_00019359 EFTA00169106 KYC Print Page 12 of 12 https://dbforcepb.my.salesforce.com/servlet/servlet.Integration?lid=01N30000000D9Di&e... CONFIDENTIAL – PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0000490 EFTA_00019360 EFTA00169107