FW: PRIME OFAC Case Escalation [C]

Good Morning:

I've got a PRIME OFAC Alert I need to escalate: 297715. It refers to an Outgoing Wire being sent to an account holder named , who has an account with SBERBANK OF RUSSIA ), which is an exact match. The account has sent a total of 3 transactions to this person at SBERBANK (see attached).

Please advise. Thanks!

Kind regards,
Danya Friedman

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Danya Friedman
PWM AML Compliance Associate
DB USA Core Corporation

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Hi Louie,

Can you please try to identify the attached transactions in OnDemand as these transactions are expected to be screened in Hotscan.

Best Regards

Felix

Sent from my BlackBerry 10 smartphone.

Felix,

Please see attached. Sorry for the delay. I was having issues with OnDemand. I had to uninstall/reinstall it.

For 15916650 it appears twice in OnDemand (CPS and FRB). Let me know if you need a pdf of the other instance (provided CPS).

The others only appear once.

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Hi Danya,

Thank you for escalation these transactions. We confirmed that the transactions are screened in Hotscan and Hotscan did not stop this transaction for . Though and are arts of OFAC SDNs, there is no evidence that is an OFAC SADN.

Best Regards

Felix

Danya/Cherie -

know that these transaction were cleared from an OFAC Perspective.

However, I I was just curious if you have looked at these from a broader AML/- Negative Media perspective. I know these a a relatively small amounts, but it seems odd that Mr. Epstein would be sending payments to various individuals in Russia.

I I suggest an inquiry to the RM to inquire why Mr. Epstein is sending periodic, small payments to an individual in Russia where the payment instructions list the name of a a woman named " " " " and no other information. You should ask to RM to find out, among other things — the specific ur ose of the payments, who is (the beneficiary) and who

Kind Regards,

Wayne Salit

Deutsche Bank Americas
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