EFTA Document EFTA01388005

14. Case Comments Created By Date Comments Kshitij Golan' 9125/118 10:04 AM T as a high riss update for the below listed c ems (together •accounthoidets") - 1 & Karyna Shuliak 2 Butterfly Trust 3. Neptune 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 - SOW: The UBO (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages client's assets. SOW verification was obtained. In addition, Karyna Shuliak is an employee at JSC Interiors. We have her pay stubs under KYC— 1790724. 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 oe on any sanctions lists. Mayur Rathod 9/3/118 3:17 AM No material changes confirmation "emair attached in the case. ONSHORE APPROVALS Client Facing Professional (CFP): Stewart Oldfield Signature) Stewart Omfiew 9 5 2018 Office Director: Business Head: &even Mattus ( Sgnature) Steven Mattus 9 6.2018 Regional Office DireOor. :Sgnature) AMI. Business Risk (Srature) AML Compliance: Kshitij Golani (Signature) Kshitij Golan' 9/25/2018 LATAM/INTERNATIONAL APPROVALS Omni Facing Professional (CFP). (Signature) Account Manager. (Signature) Gabel Market Team Head (GMTH)/Sub-Market Team Head (SMTH). ( Sgnature) AML Business Risk: (Signature) CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0091314 SDNY_GM_00237498 EFTA01388005