EFTA Document EFTA01381389

From: Thomas Klemm Sent: 11/15/2018 5:58:43 PM To: Stewart Oldfield I Subject: RE:Open 2018 HR KYCs Thanks!! From: Stewart Oldfield Sent: Donnerstag, 15. November 2018 17:55 To: Thomas Klemm < Cc: Andrew Gallivan < >; Emil Crai: < >; Da•hne Cales >; Bradley Gillin < >; Richard larossi < Subject: RE: Open 2018 HR KYCs Just spoke to Jeffrey's office. We will get the KYC info we need for the donor to Gratitude. I need to reach out to that person's office tomorrow to start to gather the info. Will report back with a timeline to get that as soon as I make contact. Thanks From: Stewart Oldfield Sent: Monday, November 05, 2018 10:00 AM To: Thomas Klemm <t homas.klemm db.corn> Cc: Andrew Gallivan >; Emily Craig Subject: RE: Open 2018 HR KYCs >; Daphne Coles Thanks, and I greatly appreciate your help. We should discuss this one in person. A brief summary of the issue is below: Gratitude America is a foundation, set up by Jeffrey Epstein to help some of his clients with tax planning One of his clients made a large donation to the foundation several years ago which is now being deemed SOW for Gratitude That client is actually one of our clients, with a current KYC, but made the donation through an entity which we have not KYC'd While we know who the end client is, we are not sure whether Jeffrey or the client want to formally disclose that info to us They are in discussions with the goal of coming back to us by Nov. 15th From: Thomas Klemm Sent: Monday, November 05, 2018 9:53 AM To: Stewart Oldfield csi ewart.oldfieIP@Pb.cpcn> Cc: Andrew Gallivan < 1 11M>, Emily Craig Subject: Open 2018 HR KYCs Dear Stewart, >; Daphne Cales First, let me thank you for your ongoing efforts to address our HR KYC challenge. Demonstrating our ability to protect the franchise and bring the Americas in line with all other WM regions is pivotal for our growth strategy. For the first time we have a line of sight to closing the year at zero HR overdues. Let me add that it requires AFC approval to count a HR file as completed. CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0080335 CONFIDENTIAL SDNY_GM_00226519 EFTA01381389