EFTA Document EFTA01362257

From: Sent: 8/23/2018 3:03:16 PM To: Thomas Klemm CC: Daphne Cales • Emily Craig • Bradley Gillin Richard larossi • Vinita Advani BCC: Subject: Thomas. Update : Case management on High Risk accounts III Below please find an update on the pending high risk completions. My recommendation to process more quickly through the cases would be to request the following two exceptions from Compliance/KYC: Certificate of Good Standing - COGS should be required every 12-15 months. Requesting this certificate every six months is (1) costly to the client: (2) annoying; and (3) time consuming. What is the rational behind the 6 month request and how was that period of time chosen for this certification; FinCen - Once we provide evidence of requesting the FinCen form from the client, we should move the KYC to the next stage with a 60 day grace period to obtain them. Updates in red below. Khullar Relationship • AMAAN HOLDINGS LLC — Due Date 06/29/2018 — Pending SoS for SAMRA Holdings Ltd (refer attached 1st email) • HATTAN HOLDINGS LLC — DueDate 06/29/2018 — Pending SoS for SAMRA Holdings Ltd (refer attached 1st email) MARSA HOLDINGS LLC — DueDate 06/29/2018 — Pending SoS for SAMRA Holdings Ltd (refer attached 1st email) o Response from client, Deepak Khullar, on 8/9/18 - 'SoS for Sarnia- letter of good standing will have to be sourced from the registrars - CITCO and could take a week to ten days' Jefferies Relationship: • JCP IV QP, LLC — DueDate 06/30/2018 — o All outstanding KYC Does received yesterday. pending review. Cerberus Relationship: • Cerbenis Executive. LLC —DueDate 07/31/2018 — Awaiting dots as per attached 3rd email. I am aware that you have followed up with client on this. so thanks for that. o Working with Cetberus' Council. FinCEN Form, Certificate of Good Standings (within 6 months), and constitutional does from 6 entities were requested. Sillerman Relationship: Aircraft Acquisition Corporation — DueDate 08/03/2018 - Awaiting dots as per 4th email attached. Sillerman Investment Company 10. LLC - DueDate 08/03/2018 - Awaiting does as per 4th email attached. Tomorrow Foundation - DucDate 08/03/2018 - Pending CDD fonn as per attached 5th email attached. Elderberry X. LLC — DueDate 08/03/201.8 — Pending CDD fonn as per attached 5th email attached. Sillerman Investment Corporation — DueDate 08/03/2018 — Awaiting does as per 4th email attached. o Requested FinCEN forms from Sillerman — should receive tomorrow/early next week. Southern Financial/Epstein Relationship: Epstein, Jeffrey E. — DueDate 08/08/2018 — Awaiting does as per attached 5th email attached. Southern Financial LLC - DueDate 08/08/2018 — Awaiting does as per attached 8th email attached. Southern Trust Company, Inc. - DueDate 08/08/2018 — Awaiting does as per attached 5th email attached. J. Epstein Virgin Islands Foundation, Inc - DueDate 08/08/2018 — Does & confirmation required as per attached 10th email GoldenTree Asset Management UK LLP- DueDate 08/09/2018 - Docs & confirmation required as per attached 11th email Gratitude America Ltd - DueDate 08/16/2018- Awaiting dots as per attached 6th email attached. Neptune, LLC - DueDate 08/16/2018 - Does required as per attached 2nd email NES, LLC - DueDate 08/16/2018 — Does & confirmation required as per attached 9th email. LSJE, LLC — DueDate 08/18/2018 — Awaiting dots as per attached 8th email attached. Hyperion Air, LLC — DueDate 08/18/2018 — Does at confirmation required as per attached 10th emit JEGE, Inc — DueDate 08/18/2018 — Awaiting confirmation at does as per attached 7th email JEGE, LLC — DueDate 08/18/2018 — Awaiting confinnation & does as per attached 7th email Plan D, LLC — DueDate 08/18/2018 — Does & confirmation required as per attached 9th email. Japers. Inc - DueDatc 08/18/2018 — Awaiting confirmation & does as per attached 7th email CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0051607 CONFIDENTIAL SDNY_GM_00197791 EFTA01362257