EFTA Document EFTA01345283

KYC Print Page 18 of 19 14. Case Comments Created By Date Comments Ti, s KYC serves as a h:gh FISK update tor the below listed cents (together taccountho!ders) - I. Gratitude America, Ltd 2. Neptune. LLC 3. NES, 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 accountholders. their purpose, the purpose of the accounts and expected transaction activity. • There are a few risk factors associated with the accountholders - Dinka Manley 8/17/117 0:36 AM SOW: SOW: The UflOs (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages clients assets. SOW verification was obtained. Negative Media 8 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 Cynthia Rodriguez 8/16/117 11:02 PM ceent confirmed on a call that there were no changes to these accounts on 7126/2017. Cynthia Rodriguez 7/13/117 7:35 PM Maze Trust and Butterfly trust have been removed from this rem ediation Nye and added to kyc case 01804531 as beneficiary Information is still pending. Cynthia Rodriguez 7/10/117 9:29 PM Source of Wealth for Jeffrey Epstein is attached. ONSHORE APPROVALS Gent Facing Professional (CFP): stewart oldfiekl (Signature) stewart oldfield 7. 52017 Office Director/Business Head Andrew F Gallivan (Signature) Andrew F Gallivan 7.6:2017 Regional Office Director: (Signature) AML Business Risk: (Signature) AML Compliance D Manley obo Kshrtij Golan[ Yoonsun Chung (Signature) 0 Manley obo Ifshrtij Golani Yoonsun Chung 8/16/2017 8/16/2017 LATAM/INTERNATIONAL APPROVALS Qient Facing Professonai (CEP) (Signature) Account Manager: (Signature) Global Market Team Head (GMTH)/Sub-Market Team Head (SMTH): (Signature) AML Business Risk: (Sgna:ve) https://dbforcepb.my.salesforce.com/serylet/servlet. Integration?lid IN30000000D9Di&e... 7/30/2018 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0031538 CONFIDENTIAL SDNY_GM_00177722 EFTA01345283