RE: APPROVAL NEEDED: High Risk RUSH KYC Case 01696913 [C]
Hello,
I am requesting Exco Approval for Zorro Management, LLC, under the Jeffrey Epstein relationship. Mr. Epstein has recently created this U.S Virgin Islands entity, and would like to open a checking account before year end.
RM Name
Stewart Oldfield
Business Line
US Onshore
GCIS # / KYC #
483290/ 01651789
New or Existing Relationship?
If yes, please include relationahip since date, approx # of accounts, AUM, etc.)
Existing relationship since 8/26/2013. A total of 21 deposit accounts and 3 money market accounts for multiple entities, 5 brokerage accounts and 1 custody account. Total AUMs $224mn.
EFTA01398720
Legal name of Account Holder(s)
Zorro Management, LLC
Name of UB0(s)
(Please include UBOs who own 25% and more; If there are multiple layers, please include description of ownership structure)
Jeffrey Epstein
Description of Type of account being opened with detailed purpose of the accounts
(Please include SOW information/ Geographic location/
For Entity Accounts: Description of the entity and background information on the UBO)
We are opening checking account for new entity, Zorro Management LLC
Reason for High Risk
This relationship is deemed high risk due to multiple court cases on Jeffrey Epstein, involving 22 April 2004 SEC filed a settled civil fraud action for illegal insider trading in three publicly traded Massachusetts banks. Final judgement permanently enjoins him from violating the antifruad provisions and he agreed to pay a total of $72532.06 in disgorgement of trading profits, prejudgment interest and civil penalties. Epstein was sentenced to 21 months in federal prison for three counts of fraud, sexually assaulting a girl and solicitation of prostitution. These alerts were previously approved by senior management and AML Compliance. Prior clearance is attached as a reference
PEP (Y/N)
If yes, include details
No
EFTA01398721
Any negative media and/or court cases?
Include ALL negative media & court cases
Yes
If Yes, please give details
Aside from the court cases listed in the reason for high risk, all other alerts were false positives and no new court cases or negative media has come up for this client.
Business Justification for the relationship despite High Risk Factors
All negative media and alerts have been reviewed by AML Compliance and they do not see a reason to discontinue the existing relationship with Jeffrey Epstein.
Kind regards,
Cynthia Rodriguez
Cynthia Rodriguez
Assistant Vice President
Deutsche Bank Trust Company Americas Deutsche Asset & Wealth Management
EFTA01398722
345 Park Avenue, 10154-0004 New York, NY, USA
Tel. (212)454-4577
Fax (646) 736-0721
Email
EFTA01398723
Hello,
I am follow up on the below. Thanks for your help!
Kind regards,
Cynthia Rodriguez
Cynthia Rodriguez
Assistant Vice President
Deutsche Bank Trust Company Americas
Deutsche Asset & Wealth Management
345 Park Avenue, 10154-0004 New York, NY, USA
Tel. (212)454-4577
Fax (646) 736-0721
Email
EFTA01398719
Can you folks remind me, wasn't this name going to WMRRC recently. I remember our discussing it.
EFTA01398718
Sent from my BlackBerry 10 smartphone.
No — I do not remember any recent discussions regarding Jeffrey Epstein. The only recent matter was Kushner and the rep risk associated with his father who was convicted of illegal campaign contributions, tax evasion and witness tampering. Could you be thinking of that?
Kimberly Hart
Managing Director I Regional Control Officer
Wealth Management Americas
Deutsche Bank Trust Company Americas
60 Wall Street, 27th Floor, New York, NY 10005
Tel. +1 212 454-2877
Fax +1 646 863-9809
Mobile +1
Email
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