EFTA Document EFTA01365507

From: Daniel Sabba Sent: 2/2/2016 7:39:20 AM To: Todd Stevens Subject: RE: Epstein account opening [I] It is a report done by kroll report that costs S800 or so. RRC asked for it. See other email. Original Message-- From: Todd Stevens Sent: Tuesday, February 02, 2016 03:51 AM Pacific Standard Time To: Daniel Sabba Subject: RE: Epstein account opening [1] Classification: Public Got it.. what is a ...external enhanced due diligence report? From: Daniel Sabba Sent: Tuesday, February 02, 2016 11:38 AM To: Todd Stevens Subject: FW: Epstein account opening [I] Original Message From: Daniel Sabba Sent: Monday, February 01, 2016 12:05 PM Pacific Standard Time To: Todd Stevens Subject: RE: Epstein account opening [I] The issue is that JE was listed as president of Gratitude America Ltd in the entity's original articles of incorporation. Additionally, JE was listed as the source of funds in the initial KYC done by Paul's team. When Ari reached out to Middle Office, they looked at the KYC and flagged the request as "high risk" and asked us to get AML approval. As you recall, we already went to AML (Wayne Salit) to ask whether the account opening could be done. Wayne was the one who referred us to RRC. When we went to the RRC, they requested an external updated Enhanced Due Diligence Report. The entire back and forth over the past week is on the request for this report, which is under Paul's review for sign-off. In summary, first, the KYC does not reflect this is a separate relationship. Second, given the post-facto nature of the changes in the article of incorporation, I think AML/RRC are very likely to still require the due diligence report. From: Todd Stevens Sent: Friday, January 29, 2016 4:59 PM To: Daniel Sabba Subject: Fwd: Epstein account opening [I] Thoughts? What is JE's role here? CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0056269 CONFIDENTIAL SDNY_GM_00202453 EFTA01365507