RE: EDD package for the RID : ONB-120902 LKYCUS-3443 Party name : Southern Financial LLC [I]

Hi Team,

Attached below is the EDD Package for RID - ONB - 120902 Southern Financial LLC. Captioned request is principal party set up and it is a Private Investment Vehicle.Request is raised for DBSI- Equity - custody/- Margin (Type 1).

We are escalating the request as Entity is Private Investment Vehicle.

Kameshwaran has reviewed the alerts and the same has been attached for your reference.

"Jofin reviewed and QA'd this EDD escalation package and confirms that all appropriate documentation is being escalated."

The request has been escalated to AML Compliance. Kindly do the needful.

EDD Template and 5 AML answers [attachment "EDD template and 5 AML answers.pdf" deleted by Dmitri Saks/db/- dbcom]

CIP Document

[attachment "1 - CIP Doc.pdf" deleted by Dmitri Saks/db/dbcom] Physical Email

[attachment "CIP e-mail.pdf" deleted by Dmitri Saks/db/dbcom]

CP Proof

[attachment "CP Proof.pdf" deleted by Dmitri Saks/db/dbcom]

UBO Proof

[attachment "UBO.PDF" deleted by Dmitri Saks/db/dbcom]

ID Proof

[attachment "5 - UBO - ID.pdf" deleted by Dmitri Saks/db/dbcom] AML Checks on Entity, CP and UBO

[attachment "3 - AML Checks.pdf" deleted by Dmitri Saks/db/dbcom] Internal Review

[attachment "Alert Review.pdf" deleted by Dmitri Saks/db/dbcom] Confirmation on Private investment vehicle

[attachment "Confirmation.pdf" deleted by Dmitri Saks/db/dbcom]

Kind regards,
Sujith Shetty

Sujith Shetty

DBOI Global Services Private Limited
Velankani Tech park, No 43, Electronic City, Hosur Road„ 560100 Bangalore, India
Mobil
Email

HI Dmitri,

The Document is signed by the UBO himself however adding to it there are two more Individuals executed the same doc who are the part of Board of Directors. As per the procedure it states we can not consider the UBO verification confirmed by UBO himself only however considering the execution of the Board of Directors in the operating agreement we have accepted the UBO document. Kindly let us know if you want us to go back

Kind regards,
Jofin Varghese

Client Onboarding - NY CAG
DBOI Global Services Private Limited
IB operations
Velankani Tech park, No 43, Electronic City, Hosur Road„ 560100 Bangalore, India
Tel. Mobile
Email
Escala ion oin :
Back Up

Hello All,

Please note that the UBO verification document is signed by the alleged UBO himself and may not be accepted as such. Please follow the CB&S U.S. AML Due Diligence Requirements to verify ownership:

Obtain information on the organizational structure of the customer to the natural person level (direct or indirect UBOs of 25% or greater). Such information may be obtained through one or more of the following methods:

• Organizational Chart OR

• Letter/e-mail from Internal Counsel, Compliance Officer or Senior Manager (e.g., Control person) OR

• Letter/e-mail from External Counsel OR

• Use of publicly available information (e.g., trusted website) OR

• Use of documentation (e.g., Registry Filing, legal document, etc.)

Should you have any questions, please contact us.

Thank you,

US CB&S AML Compliance
AML Compliance

Deutsche Bank Securities Inc.
Compliance

HI Dmitri,

The UBO is the sole controlling person of our entity however the Board of Directors who executed the operating agreement are the part of the Parent company. We have Considered the confirmation from the BOD of the parent entity which is an independent execution. While the procedure indicated to accept the UBO confirmation provided by the board of director either through an client email or Letter head or formal legal agreements. Kindly provide your view on the same

Kind regards,
Jofin Varghese

Client Onboarding - NY CAG
DBOI Global Services Private Limited
IB operations
Velankani Tech park, No 43, Electronic City, Hosur Road„ 560100 Bangalore, India
Tel. Mobile
Email
Escala ion oin :
Back Up:

Hi Anastasia,

As advised by AML Compliance in the below mail, we would be requiring a revised ownership confirmation to proceed further with the adoption of the captioned entity, Southern Financial LLC.

Request you to help us obtain the same.

Thanks and Regards,
Manikandan Muralidharan

Manikandan Muralidharan
U S - New Client Adoption

DBOI Global Services Private Limited
Block 5, 6, 7, Velankani Tech Park, No.:43, Electronic City, Hosur Road, 560100 Bangalore, India
Tel. █████████████████████
Mobile █████████████████████
Email █████████████████████████████████████

Backup details -
Ganesh Balaji (██████████████████████████)
Bharath-Kumar MS (████████████████████████████████)

For Escalations please contact

MS EFTA01417991

Level 1 Karthik
Level 2 - Balaji /Kumud

Hi Jofin,

As stated in the attached, Jeffrey Epstein is the only control person, hence the "conflict of interest supposition" still exists. Besides, the supplied Board of Directors paper is neither notarized/witnessed/certified nor represents a formal filing document. In other words, it is not a strong legal proof. In such cases we recommend requesting a letter/email from an internal or external legal counsel.

Thanks and regards,
Dmitri

Dmitri Saks
AML Compliance Officer

Deutsche Bank Securities Inc.
60 Wall Street, New York, NY 10005-2836
Tel:
E-mail:

Jofin,

Please note that the provided Board resolution is the document of Southern Trust Company, Inc., and not Southern Financial LLC. Therefore, the following key statements made within the document will need to be validated:

"Epstein is also the sole shareholder of Corporation" (i.e., Southern Trust Company, Inc.), and "the Corporation is the sole member of Southern Financial LLC"

In order to validate the above, please provide the following supporting documentation:

For Southern Trust Company, Inc.: proof of incorporation/formation and proof of appointment of the board of directors. You will also need to identify the board members as control persons for this account since they would be controlling Southern Financial LLC through Southern Trust Company, Inc. PCR/RDC searches would also be required. For Southern Financial LLC: Operating Agreement or other valid proof that Southern Trust Company, Inc. is the sole member of Southern Financial LLC.

Alternatively, as I stated before, you can provide a letter/email from an internal or external legal counsel stating that Mr. Epstein is the sole UBO of Southern Financial LLC.

Thanks and regards,
Dmitri

Dmitri Saks
AML Compliance Officer

Deutsche Bank Securities Inc.
60 Wall Street, New York, NY 10005-2836
Tel: █████████████████
E-mail: █████████████████████

Mani/Dmitri

Please see the attached documents.

Please advise if there is anything additional needed.

Hi Anastasia,

Per your request, please find attached the following:

1. Southern Trust: All incorporation documents

2. Southern Financial: Operating Agreement and incorporation documents

In each document package, please disregard the DB PWM brokerage account documents, as they are not relevant. Please reach out with any further questions. Thank you.

Thanks

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc. Client Onboarding Equities 5022 Gate Parkwa , Suite 500, 32256 Jacksonville, FL, USA

Tel
Fax
Email

Please send all GED related emails to: ████████████████

Anastasia,

Thank you, this is helpful. However, a proof of appointment of the Board of Southern Trust Company, Inc. (Jeffrey Epstein, Darren K. Indyke, Richard Kahn) is still required. This is because they signed the UBO confirmation document stating that Mr. Epstein is the sole shareholder of Southern Trust Company, Inc.

Also, Darren K. Indyke and Richard Kahn need to be identified as control persons in addition to Jeffrey Epstein, and the PCR/RDC checks for them need to be run and documented. This is because they control Southern Trust Company, Inc. which is the sole member of Southern Financial LLC.

Thanks and regards,
Dmitri

Dmitri Saks
AML Compliance Officer

Deutsche Bank Securities Inc.
60 Wall Street, New York, NY 10005-2836
Tel:
E-mai :

Hi Dmitri,

We have got the alert review for the RDC alert received on Richard Kahn. During the alert review, we have found that these alerts are false positive.

Please refer to the below mail with regard to Alert review for your reference.

Please let us know, if anything is required from our end.

Thanks and Regards,
Manikandan Muralidharan

Manikandan Muralidharan

U S - New Client Adoption

DB0I Global Services Private Limited
Block 5, 6, 7, Velankani Tech Park, No.:43, Electronic City, Hosur Road, 560100 Bangalore, India
Tel.:
Mob.:
Email:

Backup details -
Ganesh Balaji ( )
Bharath-Kumar MS ( )

For Escalations please contact
Level 1 - Karthik
Level 2 - Balaji /Kumud

Hi Dmitri,

Can you please advise on the current status?

Thanks

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway, Suite 500, 32256 Jacksonville, FL, USA
Tel.
Fax
Emai

Please send all GED related emails to:

Anastasia,

The case has been submitted to the next level of approval.

Thank you,

US CB&S AML Compliance
AML Compliance

Deutsche Bank Securities Inc.
Compliance

Hello Dmitri,

Please see the background checks for the additional 2 CP's.

Please give an update to this request as soon as you can.

Thank you

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway, Suite 500. 32256 Jacksonville, FL, USA
Tel.
Fax
Emai

Please send all GED related emails to:

Hi Team,

Request you review the RDC hit received on "Richard Kahn, one of the board of director of Parent entity, Southern Trust Company Inc.

(See attached file: Additional AML checks on Parent entity, board of director.pdf)

Additional document

(See attached file: 5 - SFLLC UBO.PDF)

Thanks and Regards,
Manikandan Muralidharan

Manikandan Muralidharan
U S - New Client Adoption

DB0I Global Services Private Limited
Block 5, 6, 7, Velankani Tech Park, No.:43, Electronic City, Hosur Road, 560100 Bangalore, India

Tel.

Mobile

Email

Backup details
Ganesh Balaji
Bharath Kumar MS

For Escalations please contact ████████████
Level 1 - Karthik ████████████
Level 2 - Balaji (██████████)/Kumud

Hello All,

Please find the details below:

NO ESCALATION REQUIRED

1. Richard Kahn

Alert #1:

Alert is False Positive. Mismatch Individuals. Our client name is Richard Kahn who is controlling person of Southern Financial LLC. Whereas, Alerted Individual name is Richard Jeffrey Kahn who is Wells Fargo Employee and was fined for unregistered activity.

http://www.bizjournals.com/southflorida/search?-
q=%22Jeffrey+Kahn%22&title=%3 Fiframe%3Dtrue&width=95%25&height=95%25+title%3-
D+title%3D+title%3D+title%3D%20title=

Alert #2:

Alert is False Positive. Mismatch Individuals. Alerted Individual Name is Richard Kahn who violated NYSE Arca Equities Rule by failing to provide testimony as requested by FINRA.

https://www.google.co.in/url?url=https://www.nyse.com/pdfs/12-
ARCA-3.pdf&rct=j&frm=1&q=&esrc=s&sa=U&ei=MD6UVIedDSWPuAT924D0CQ&ved=0CBMQFjA-
A&usg=AFQjCNH6TerGChaK_BRHqY5DUNOCAX7ziw

Alert #3:

Alert is False Positive. Alerted Individual Richard L Kahn is not related to any entity and is a drug dealer as per internal research. Hence no escalation required.

NOTE: PCR is NO HIT

Kind regards,

Syed-Anzar Ahmed Process Supervisor I COB - RDC LOOKBACK TEAM

DBOI Global Services Private Limited
Global Business Services
VTP Electronic City Hosur Road, 560100 Bangalore, India
Tel
Mobile

Good morning,

Do we have an update on the below request.

Thanks

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway, 500, 32256 Jacksonville, FL, USA
Tel.
Fax (
Email

Please send all GED related emails to:

Hello Anastasia,

Could you please help to identify the Head of the Business through which this client is being onboarded. AML Compliance needs to have a discussion prior to approving this account.

Thank you.

US CB&S AML Compliance
AML Compliance

Deutsche Bank Securities Inc.
Compliance

Courteney/Mark,

Who is the head of the business for this request.

Thanks

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway, Suite 500, 32256 Jacksonville, FL, USA
Tel.
Fax
Ema

Please send all GED related emails to:

Anastasia, that would be me. What is the issue?

Dmitri,

Please speak with Courteney as she would be the responsible party for this request.

Thanks

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway, Suite 500, 32256 Jacksonville, FL, USA
Tel
Fax
Ema

Please send all GED related emails to:

Dmitri,

Please advise on the status of this, is this request still pending with AML?

Thanks

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway, Suite 500, 32256 Jacksonville, FL, USA
Tel.
Fax
Ema

Please send all GED related emails to:

Hi Anastasia,

Yes, it is still pending. I should be able to provide a more definite answer tomorrow.

Thanks and regards,
Dmitri

Dmitri Saks
AML Compliance Officer

Deutsche Bank Securities Inc.
60 Wall Street, New York, NY 10005-2836
Tel:
E-mail:

Dmitri-

Can you tell us why this is taking so long? It's been with AML with several weeks now, correct?

Courteney Fornal

Global Markets Complex Equity

Deutsche Bank Securities Inc.
60 Wall Street

New York, NY 10005-2836
Direct: [REDACTED]
Desk: [REDACTED]
Fax: [REDACTED]
Email: [REDACTED]

Courtney,

This requires a discussion between the AML and the Business Senior management. The delay is due to the challenge in coordinating this effort because of the Holiday schedule.

Thanks and regards,
Dmitri

Dmitri Saks
AML Compliance Officer
Deutsche Bank Securities Inc.
60 Wall Street New York, NY 10005-2836
Tel:
E-mail:

Hello Dmitri,

Any word on the discussion for this request?

Thanks

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway Suite 500 32256 Jacksonville, FL, USA
Tel.
Fax
Emai

Please send all GED related emails to:

Hi Anastasia,

The latest information I have is that Ted Gonedes intends to discuss this issue with Courteney next week.

Thanks and regards,
Dmitri

Dmitri Saks
AML Compliance Officer

Deutsche Bank Securities Inc.
60 Wall Street, New York, NY 10005-2836
Tel: ██████████████
E-mail: ██████████████

Hello Courteney,

Has the below discussion between yourself and Ted taken place yet?

Please advise, as this request will need to be closed out this week in order to not be cancelled in the system .

Thanks

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway, Suite 500, 32256 Jacksonville, FL, USA

It has not...Ted has been out of the office but he will be in tomorrow.

Courteney Fornal

Global Markets Complex Equity

Deutsche Bank Securities Inc.
60 Wall Street

The image is not a chart. It displays contact information for Deutsche Bank Securities Inc. at 60 Wall Street, New York, NY 10005-2836. The specific contact details for Direct, Desk, Fax, and Email are redacted.

Dmitri,

Please advise if you have received the necessary information yet in order to approve this request?

If we do not get the necessary by EOD tomorrow, the request will be placed on on-boarding. hold and reinitiated once we have what we need to complete the

Thanks

Kind Regards,

Mrs. Anastasia Pringle

Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway, Suite 500, 32256 Jacksonville, FL, USA
Tel.
Fax
Ema

Please send all GED related emails to:

Anastasia,

I have not been notified of any further developments in this case.

Thanks and regards,

Dmitri

Dmitri Saks
AML Compliance Officer

Deutsche Bank Securities Inc.
60 Wall Street New York NY 10005-2836
Tel:
E-mai