EFTA Document EFTA01368142

FINRA Is the client FINRA 2111 suitable? FINRA 2111 is not applicable for all products, please refer to Key Operating Procedures N/A Market Participant Identifier Is the client a broker/dealer Escalation Have you come across any other reason for escalation to AML Compliance? No Enhanced Due Diligence Is Enhanced Due Diligence required ? Yes What type of account is the client opering with CIB? Equities -Custody/Margin Who is their Registered Supervisor? Courteney Fomal 100% money of Jeff Epstein from his work in the financial industry. Source of funds for Southern Financial LLC is that of Jeffrey Epstein. What is the Epstein began his financial career in 1976 as an options trader at Bear Stearns and became a partner in 1980. In 1982, Epstein founded his own client's financial management firm, J. Epstein 8 Co., managing the assets of clients with more than a billion in net worth. In 1996, Epstein changed the source of name of his firm to The Financial Trust Company and based it on the island of St. Thomas in the US Virgin Islands which merged into Southern finds? Financial LLC. All of his clients were anonymous except for the very wealthy businessman Leslie Wexner. His wealth has come from his days at Bear Stearns and his financial management firms What is the client's line of business? Private Investor What is their expected activity? Flow trading Foreign Financial Institution Is an account being opened for a foreign financial institution' ('FFI") registered and/or domiciled in either a Level 3 or 4 Country ? ' Foreign financial institutions as defined within Section 312 of the USA PATRIOT Act are Non-U.S banks, broker dealers, futures commission merchants, Introducing No brokers in commodities, mutual finds money transmitters or currency exchangers and private banking accounts. AFC Escalation Form For United Kingdom General Information Entity Legal Name: KYC Type Southern Financial, LLC Private Entity Nace Code 6713003 Nace Description Activities auxiliary to financial intermediation n.e.c. Global risk rating HIGH Local risk rating HIGH Entity Role Contracting Party Page 15 CONFIDENTIAL - PURSUANT TO FED. R. CRI M. P. 6(e) DB-SDNY-0059803 CONFIDENTIAL SDNY_GM_00205987 EFTA01368142