RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# N4G024943, Alert# SAM1788880 [I]
Good Morning:
As a part of the anti-money laundering monitoring program, the Actimize system is used to automatically identify transactions that meet certain high risk transaction patterns. When transactions occur which mimic those patterns, the activity must be researched to confirm that it is legitimate.
In a small percentage of these cases, Compliance must contact the Wealth Advisor for additional information about the transaction(s) in order to conclude the research process. Your response is required for the Bank to comply with federal guidelines for concluding the research of these matters in a timely fashion. Your complete response must be received within 7 business days.
To the best of your ability, please provide details regarding the item(s) below:
Incoming:
10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION
- Who is the ultimate originator of these funds (i.e. if this is investment income, please give the name of the investment that the funds originate)?
Outgoing:
11/23/2016, $25,000,000.00, AP NARROWS HOLDING LP/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA, N.A., NY
11/23/2016, $5,000,000.00, LDB 2011 LLC/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA, N.A., NY
What is the purpose of the Outgoing Transfer?
What is the relationship between Beneficiary and Client?
Please provide the source of wealth for these entities.
Thank you in advance for your prompt attention to this matter.
Best Regards/Mit freundlichen GrOgen,
PWM AML Compliance
Deutsche Bank
60 Wall St., 23 Floor
New York, NY 10005 - 2836
Fax:
PLEASE NOTE: YOU ARE BEING CONTACTED BECAUSE YOU ARE LISTED AS THE PRIMARY OFFICER FOR THIS ACCOUNT ON GCIS. IF YOU ARE NOT THE CURRENT PRIMARY OFFICER, PLEASE LET ME KNOW IMMEDIATELY, SO THAT I MAY FORWARD THIS EMAIL TO THE APPROPRIATE PARTY.
Do not forward this e-mail or any attachment directly to the client.
Vahe,
Please follow up.
Reason — purchase of art.
Thanks
Ziggy
Adding Stewart Oldfield, primary relationship manager who can confirm the below.
- What is the purpose of the Outgoing Transfer?
Purchase of Art.
- What is the relationship between Beneficiary and Client?
Per our conversation with client — the beneficiary in this situation is an escrow account in which the cash will be held until art is delivered.
- Please provide the source of wealth for these entities.
Stewart — can you please add here the Private Bank KYC, which I believe includes the SOW for this client? Thank you.
Best,
Vahe
Cynthia is back Monday and will send all of the docs then. Thanks
Good Morning and thank you for the quick response. Just to clarify, the below response is only answering my questions regarding the Outgoing Transfers and both of these transfers were towards the purchase of art? We will need the ultimate originator for the Incoming Transfer. Also, once again, just to clarify, we have the KYC on the HAZE TRUST, we need the source of wealth for the beneficiaries if available.
Thanks again! I hope everyone has a great weekend!
Best Regards/Mit freundlichen Grüßen,
PWM AML Compliance
Deutsche Bank
60 Wall St., 23 Floor
New York, NY 10005 - 2836
Fax:
Just to clarify, the funds came in from client's Private bank account (in house — from DBTCA account/PB into his DBSI account).
Thanks
Ziggy
Please specify the originating account so that I can confirm this transaction, after searching PRIME and DB FORCE (our PB systems, I am unable to locate the transaction). Also, any idea as to why, if this is an internal transfer, that funds are being sent through HSBC?
Best Regards/Mit freundlichen Grüßen,
PWM AML Compliance
Deutsche Bank
60 Wall St., 23 Floor
New York, NY 10005 - 2836
Fax:
All,
The originating wire came from the client's account called Southern Trust Company, Inc account number 44129244. This wire was not submitted through HSBC but through Bank of New York in order to be placed into their N4G account for the art purchase. The beneficiary is our client Jeffery Epstein as the originating party and the art purchaser. Please let me know if you need anything else.
Kind regards,
Cynthia Rodriguez
Thank you for the response Cynthia.
Team, this is not the wire I am asking about. Please see the incoming wire listed below from HSBC. I see the $23,000,000.00 incoming wire from the Private Bank account and that is not/was never in question. I need to know where these funds originate.
10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION
Best Regards/Mit freundlichen Grüßen,
PWM AML Compliance
Deutsche Bank
60 Wall St., 23 Floor
New York, NY 10005 - 2836
Fax:
Good Morning:
I am writing to follow up on my inquiry below.
Thank you.
Best Regards/Mit freundlichen Grüßen,
PWM AML Compliance
Deutsche Bank
60 Wall St., 23 Floor
New York, NY 10005 - 2836
Fax:
Good Morning:
I am writing to follow up on the inquiry below. Please note that this is the 3rd request for information. Please respond ASAP.
Best Regards/Mit freundlichen Grüßen,
PWM AML Compliance
Deutsche Bank
60 Wall St., 23 Floor
New York, NY 10005 - 2836
Fax:
Vahe/Donald/Ziggy,
Do you need anything from Stew and I for the below request? We provided as much information as we could, but the transaction in question came into the brokerage account from HSBC and not from the private bank. Let us know if you need anything from us in order to complete the below. Thanks!
Kind regards,
Cynthia Rodriguez
Dear AML,
Please let us know what else you need regarding this HSBC wire so we close
the loop.
Happy holidays.
Ziggy
Good Morning:
From the initial response below, it appears that a response was given on a different wire in the amount of $23 mil between brokerage and the private bank. Can anyone answer the inquiry regarding the wire from HSBC?
Incoming:
10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC
BANK USA, NATIONAL ASSOCIATION
- Who is the ultimate originator of these funds (i.e. if this is investment income, please give the name of the investment that the funds originate)?
Best Regards/Mit freundlichen Grüßen,
PWM AML Compliance
Deutsche Bank
60 Wall St., 23 Floor
New York, NY 10005 - 2836
Fax:
We don’t know the answer. Are we supposed to reach out to client about this?
Thanks,
Vahe
Client is a billionaire. It's not like this is a specific $6mm of his. Most of his wealth comes from investments and advisory fees.
Good Morning:
Please find out where these funds originate. We need it for audit purposes.
Best Regards/Mit freundlichen Grüßen,
PWM AML Compliance
Deutsche Bank
60 Wall St., 23 Floor
New York, NY 10005 - 2836
Fax:
Will defer to you on this in terms of how to handle.
Also, you mentioned last week you wanted to catch up. I'm around until Fri afternoon — off next week.
Relatively open the next few days if you want to grab a coffee or a quick drink?
Thanks,
Vahe
And I asked Ziggy to deal with it. The request doesn't make much sense. Best answer is investments/income.
