Update: Case management on High Risk accounts [I]
Thomas,
Below please find an update on the pending high risk completions. My recommendation to process more quickly through the cases would be to request the following two exceptions from Compliance/KYC:
- Certificate of Good Standing - COGS should be required every 12-15 months. Requesting this certificate every six months is (1) costly to the client: (2) annoying; and (3) time consuming. What is the rational behind the 6 month request and how was that period of time chosen for this certification;
FinCen - Once we provide evidence of requesting the FinCen form from the client, we should move the KYC to the next stage with a 60 day grace period to obtain them.
Updates in red below.
Khullar Relationship
• AMAAN HOLDINGS LLC — Due Date 06/29/2018 — Pending SoS for SAMRA Holdings Ltd (refer attached 1st email)
• HATTAN HOLDINGS LLC — DueDate 06/29/2018 — Pending SoS for SAMRA Holdings Ltd (refer attached 1st email)
MARSA HOLDINGS LLC — DueDate 06/29/2018 — Pending SoS for SAMRA Holdings Ltd (refer attached 1st email)
o Response from client, Deepak Khullar, on 8/9/18 - 'SoS for Sarnia- letter of good standing will have to be sourced from the registrars - CITCO and could take a week to ten days'
Jefferies Relationship:
• JCP IV QP, LLC — DueDate 06/30/2018 — o All outstanding KYC Does received yesterday. pending review.
Cerberus Relationship:
• Cerbenis Executive. LLC —DueDate 07/31/2018 — Awaiting dots as per attached 3rd email. I am aware that you have followed up with client on this. so thanks for that.
- o Working with Cetberus' Council. FinCEN Form, Certificate of Good Standings (within 6 months), and constitutional does from 6 entities were requested.
Sillerman Relationship:
Aircraft Acquisition Corporation — DueDate 08/03/2018 - Awaiting dots as per 4th email attached.
Sillerman Investment Company 10. LLC - DueDate 08/03/2018 - Awaiting does as per 4th email attached.
Tomorrow Foundation - DucDate 08/03/2018 - Pending CDD fonn as per attached 5th email attached.
Elderberry X. LLC — DueDate 08/03/201.8 — Pending CDD fonn as per attached 5th email attached.
Sillerman Investment Corporation — DueDate 08/03/2018 — Awaiting does as per 4themail attached.
o [ ] Requested FinCEN forms from Sillerman — should receive tomorrow/early next week.
Southern Financial/Epstein Relationship:
Epstein, Jeffrey E. — DueDate 08/08/2018 — Awaiting does as per attached 5th email attached.
Southern Financial LLC - DueDate 08/08/2018 — Awaiting does as per attached 8th email attached.
Southern Trust Company, Inc. - DueDate 08/08/2018 — Awaiting does as per attached 5th email attached.
J. Epstein Virgin Islands Foundation, Inc - DueDate 08/08/2018 — Does & confirmation required as per attached 10th email
GoldenTree Asset Management UK LLP- DueDate 08/09/2018 - Docs & confirmation required as per attached 11th email
Gratitude America Ltd - DueDate 08/16/2018- Awaiting dots as per attached 6th email attached.
Neptune, LLC - DueDate 08/16/2018 - Does required as per attached 2nd email
NES, LLC - DueDate 08/16/2018 — Does & confirmation required as per attached 9th email.
LSJE, LLC — DueDate 08/18/2018 — Awaiting dots as per attached 8th email attached.
Hyperion Air, LLC — DueDate 08/18/2018 — Does at confirmation required as per attached 10th emit
JEGE, Inc — DueDate 08/18/2018 — Awaiting confirmation at does as per attached 7th email
JEGE, LLC — DueDate 08/18/2018 — Awaiting confinnation & does as per attached 7th email
Plan D, LLC — DueDate 08/18/2018 — Does & confirmation required as per attached 9th email.
Japers. Inc - DueDatc 08/18/2018 — Awaiting confirmation & does as per attached 7th email
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL