EFTA Document EFTA01356008

KYC Print Page 21 of 22 H. CMS Comments Created By Date Comments Kshitij Golan/ 818/117 4:45 PM The KM serves as a high war update tor the below listed cents (togenter taccountho!ders") - I Southern Financet, LLC 2 Southern Trust Company, Inc 3 Jeffrey Epstein 4 J. Epstein Virgin Islands Foundation, Inc 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, :heir purpose, the purpose of the accounts and expected transaction activity. • There are a few risk factors associated with the accountholders - SOW: The U8Os (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 De on any sanctions lists Cynthia Rodriguez 7/71117 1:50 PM Verification of Address for Jeffrey Epstein is attached. it is his most recent paycheck from Southern Trust Company Inc. Cynthia Rodriguez 6;30/117 1:28 PM google searches for UBO can be found in KYC case Cynthia Rodriguez 717/117 2:28 PM client confirmed no material changes on 07/01/2017 via phone Cynthia Rodnguez 7/7/117 2:17 PM research for Jean Anne Brennan Weigel:lit is attached to kyc case ONSHORE APPROVALS Client Facing Professional (CFP) s:ewart oldfield (Signature) stewart afield 7/5/2017 Office Director/Business Head Andrew F Gallivan (Signature) Andrew F Gallivan 7/6/2017 Regional Office Director: (Signature) AML Business Risk: (Signature) MIL Compliance: Kshiti) Golan' Yoonsun Chung (Signature) Kshitij Golan' Yoonsun Chung 818/2017 818/2017 LATAM/INTERNATIONAL APPROVALS Gent Facing Professona iCFai (Signature) Account Manager (Signature) (Signature) https://dbforcepb.my.salesforce.com/serylet/servlet. Integration?lid IN30000000D9Di&e... 1/11/2018 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0041396 CONFIDENTIAL SDNY_GM_00187580 EFTA01356008