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sd-10-EFTA01358415Dept. of JusticeOther

EFTA Document EFTA01358415

From: Xavier Avila . Sent: 4/4/2018 5:18:47 PM To: Mathew Negus Zack Bunimovich CC: Martin Zeman • Anthon Lentini Daniel-E Kaiser Ian Salters Subject: RE: Southern Financial RDC Alerts ill Nina told me it's me that I need to approve this instead of Martin, so I approve. Matt, let's discuss this client and RDC Alerts, this client has gone through a tremendous amount of scrutiny at WM KYC level and management decision is that we are engaging the client. Thanks Xavi From: Mathew

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Dept. of Justice
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sd-10-EFTA01358415
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From: Xavier Avila . Sent: 4/4/2018 5:18:47 PM To: Mathew Negus Zack Bunimovich CC: Martin Zeman • Anthon Lentini Daniel-E Kaiser Ian Salters Subject: RE: Southern Financial RDC Alerts ill Nina told me it's me that I need to approve this instead of Martin, so I approve. Matt, let's discuss this client and RDC Alerts, this client has gone through a tremendous amount of scrutiny at WM KYC level and management decision is that we are engaging the client. Thanks Xavi From: Mathew

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Text extracted via OCR from the original document. May contain errors from the scanning process.
From: Xavier Avila . Sent: 4/4/2018 5:18:47 PM To: Mathew Negus Zack Bunimovich CC: Martin Zeman • Anthon Lentini Daniel-E Kaiser Ian Salters Subject: RE: Southern Financial RDC Alerts ill Nina told me it's me that I need to approve this instead of Martin, so I approve. Matt, let's discuss this client and RDC Alerts, this client has gone through a tremendous amount of scrutiny at WM KYC level and management decision is that we are engaging the client. Thanks Xavi From: Mathew Negus Sent: Wednesday, April 04, 2018 1:57 PM To: Zack Bunimovich Cc: Martin Zeman Subject: RE: Southern Financial RDC Alerts Ill Yes From: Martin Zeman Sent: Tuesday, April 03, 2018 1:01 PM To: Zack Bunimovich Anthony Lentini avier Avila Cc: Anthony Lentini Subject: RE: Southern Financial RDC Alerts (II Acknowledged. Please proceed with onboarding. Mat — please confirm the same to Zack. Martin From: Zack Bunimovich Sent: Tuesday, April 03, 2018 12:24 PM To: Mathew Negus Cc: Martin Zeman Subject: Southern Financial RDC Alerts Ill Mathew Negus Xavier Avila avier Avila Anthony Lentini Mat/Xavier, We received a few RDC alerts for Jeffery Epstein, sole shareholder of Southern Financial. Please see them attached. Can you acknowledge these hits and confirm that you would like to proceed with onboarding the client? Thanks, CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0046086 CONFIDENTIAL SDNY_GM_00192270 EFTA01358415

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• W-9 • Organization Chart o Per attachment "Southern Financial Operating Agreement" (pages 1, 16) • Southern Trust Company Inc. is the sole member of Southern Financial LLC Jeffrey Epstein is the sole shareholder of Southern Trust Company inc. • UBOs (Owners) that own greater than 10% o Jeffrey Epstein is the sole U80 (see "Organization Chart" above) • The source of funds for the UBOs (owners) that are greater than 10% o Jeffery Epstein began his financial career in the mid 70s

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