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.
"..lofin 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
EFTA01420463
[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
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Sujith Shetty
DBOI Global Services Private Limited Velankani Tech park, No 43, Electronic City, Hosur Road„ 560100 Bangalore, India
EFTA01420464
Mobile +0 9980030658
Email sujith.shetty@db.com
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[attachment "CP Proof.pdf" deleted by Jofin Varghese/db/dbcom] (See attached file: [Untitled].pdf)
EFTA01420465
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
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Kind regards,
Jofin Varghese
Client Onboarding - NY CAG
EFTA01420459
DBOI Global Services Private Limited
IB operations
Velankani Tech park, No 43, Electronic City, Hosur Road„ 560100 Bangalore,
India
Tel. Mobile
Email
Escalation Point:
Back Up:
{Inactive hide details for US-CB S-AML---12/17/2014 04:31:50 AM--- S-AML---12/17/2014 Classification: All, Please note For 04:31:50 that internal the AM---Classification: UBO use verification only Hello document All, For Please internal is s note use t}US-CB only Hello
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.
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EFTA01420461
US CB&S AML Compliance
AML Compliance
Deutsche Bank Securities Inc.
Compliance
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{Inactive hide details for Sujith Shetty---12/15/2014 03:49:38 PM--- Classification: For internal use only Hi Team, Attached bel}Sujith Shetty---12/15/2014 03:49:38 PM---Classification: For internal use only Hi Team, Attached below is the EDD Package for RID - ONB - 1
HI Dmitri,
The UBO is the sole controlling person of our entity however the Board of
EFTA01420456
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
Escalation Point:
Back Up:
{Inactive hide details for Dmitri Saks---12/17/2014 08 :30:54 PM---
Classification: For internal use only Hi Jofin,}Dmitri Saks---12/17/2014
08:30:54 PM---Classification: For internal use only Hi Jofin,
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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
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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
- EFTA01420453
Backup details
Ganesh Balaji
Bharath Kumar MS
For Escalations please contact
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,
EFTA01420458
Dmitri
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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,
EFTA01420455
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
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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:
Southern Trust: All incorporation documents
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
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EFTA01420452
Kind Regards,
Mrs. Anastasia Pringle
Deutsche Bank Securities Inc.
Client Onboarding Equities
5022 Gate Parkway, Suite 500, 32256 Jacksonville, FL, USA
Tel.
Fax
Email
Please send all GED related emails to: Ged.account-opening@db.com
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.
EFTA01420451
Thanks and regards,
Dmitri
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Dmitri Saks
AML Compliance Officer
Deutsche Bank Securities Inc.
60 Wall Street, New York, NY 10005-2836
Tel:
E-mail:
Anastasia,
The case has been submitted to the next level of approval.
Thank you,
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US CB&S AML Compliance
AML Compliance
Deutsche Bank Securities Inc.
Compliance
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{Inactive hide details for Anastasia Pringle---12/19/2014 02:43:57 PM---
Classification: For internal use only Hi Dmitri,}Anastasia
Pringle---12/19/2014 02:43:57 PM---Classification: For internal use only Hi
Dmitri,
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EFTA01420442
Classification: For internal use only
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
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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: Ged.account-opening@db.com
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.
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US CB&S AML Compliance
AML Compliance
Deutsche Bank Securities Inc.
Compliance
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{Inactive hide details for Anastasia Pringle---12/22/2014 10:43:18 AM--- Classification: For internal use only Good morning,}Anastasia Pringle---12/22/2014 10:43:18 AM---Classification: For internal use only Good morning,
Courteney/Mark,
Who is the head of the business for this request.
Thanks
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Kind Regards,
Mrs. Anastasia Pringle
Deutsche Bank Securities Inc
Client Onboarding Equities
5022 Gate Parkway, Suite 500, 32256 Jacksonville, FL, USA
Tel.
Fax
Email
Please send all GED related emails to: Ged.account-opening@db.com
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EFTA01420439
Hello Wayne,
From the information listed below, it appears that Courteney B Formal is the head for this request.
Kind regards,
Carlos Garcia
Hi Wayne,
The correct spelling of Courteney's last name is Fornal. She is Director and Registered Principal for the deal. Courteney is on vacation, but she's checking her email and would be available for a chat. Jan and I actually spoke with her a few days ago on a separate topic. I don't believe she's high enough for our purposes but we could definitely start with her.
The Managing Director for this business is William Shelton. He's out on an MTA and this is his out-of-office message: "I am on my mandatory time away with no access to e-mail. I will be back in the office on Friday, January 2nd. For immediate assistance, please call the desk at For emergencies, my mobile number is
The ultimate head of the Business is Ted Gonedes, Global Head of Equity Derivatives Sales for CB&S Markets (sits here in NY). He's also on an MTA and will be back next Monday, December 29.
Thanks and regards,
Dmitri
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Dmitri Saks
AML Compliance Officer
EFTA01420436
Deutsche Bank Securities Inc.
60 Wall Street, New York, NY 10005-2836
Tel:
E-mail:
John -
See information below. Are you familiar with Ted Gonedes? I am trying to figure out if he is senior enough for this decision. Also, the directory does not indicate who Ted reports into.
Let me know your thoughts on whether Ted is the right person to go to with this Rep Risk issue?
Thanks.
Kind Regards,
Wayne Salit
EFTA01420435
Yes, he is. Copying Mike who covers this space from a Line Advisory perspective.