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s as. ONSHORE APPROVALS Stewart Oldfield ;Signature) Stewart Wield 10/15/2018 cent Facing fig/L....lona' (CFP): Office Drector/Busness Head: Andrew F Gallivan (Signature) Andrew F Gallivan 101150018 Regional Office Drector: (Signature) NIL Business Risk: (Signature) AML Compliance: Richard Corbel!
OW: The 1160 (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages client's asset. SOW verification was obtained. -Negative Media & PEP: There is some negative media against Pt. Epstein and he is also maintains a close relatinship with Bill Clinton and Prime Andrew. Please see risk c
s. ONSHORE APPROVALS Client Facing Professional (CFP): Stewart Oldfiekl (Signature) Stewart Oldfield 10/15/2018 Office Director/Business Head: Andrew F Gallivan (Signature) Andrew F Gallivan 10/15/2018 Regional Office Director: (Signature) AML Business Risk: (Signature) AML Compliance: Richard Cottre
SOW: The U8O (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages clients assets. SOW verification was obtained. -Negative Media & PEP: There is some negative media against Mr. Epstein and he is also maintains a close relationship with Bill Clinton and Prince Andrew. Please see risk
ase ONSHORE APPROVALS Client Facing Professional (CFP): Stewart Oilfield ‘Signature) otewart Oldfield 9/28/2018 Office Director/Business Head: Andrew F Gallivan (Signature) Andrew F Gallivan 9/28/2018 Regional Office Director: ‘1Signature) AML Business Risk: (Signature) AML Compliance. Sandra Tlmpone
OW: The U80 (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages client's assets. SOW verification was obtained. -Negative Media & PEP: There Is some negative media against Mr. Epstein and he Is also maintains a close relationship with 84II Clinton and Prince Andrew. Please see risk
ase ONSHORE APPROVALS Client Fadng Professaanal (CFP): Stewart Oldfield (Signature) Stewart Oldfield 9/28/2018 Office Director/Business Head: Andrew F Gallivan (Signature) Andrew F Gallivan 9/28/2018 Regional Office Director. (Signature) AML Business Risk: (Signature) *IL Compliance: Sandra Timpone
SOW: The UBO (Jeffrey Epstein) IS the fourder of Southern Trust Company Inc which manages client's assets. SOW verification was obtained. -Negative Media & PEP: There is sane negative media against Mr. Epstein and he is also maintains a close rdadonship with Bill Ointon and Prince Andrew. Please see risk ca
s. ONSHORE APPROVALS Client Facing Professional (CFP): Stewart Oldfield :Signature) Stewart Oldheld 10/15/2018 Office Director/Business Head: Andrew F Gallivan (Signature) Andrew F Gallivan 10/15/2018 Regional Office Director: (Signature) AML Business Risk: (Signature) AML Comp&ance: Richard Cottrel
— -SOW: The UBO (Jeffrei Epstein) is the fonder of Southern Trust Company Inc, which manages dent's assets. SOW verification was obtained. -NegatNe Media & PEP. There is some negative media against Mr. Epstein and he Is also maintains a dose reLationsiw with all Ointon and Prime Andrew. Meese see risk calcu
Entities connected to both Andrew F Gallivan and Media & PEP

Prince Andrew
PERSON
Jeffrey Epstein
PERSONSouthern Trust Company
ORGANIZATION
Bill Clinton
PERSON
Paul Volcker
PERSON
Eric Holder
PERSONDarren Indyke
PERSON
Martha Stewart
PERSON
John Brennan
PERSON
U.S. Virgin Islands
LOCATION
Financial Trust Company
ORGANIZATIONMartindale-Hubbell
ORGANIZATION
Les Wexner
PERSONDeutsche Bank Americas New York
ORGANIZATIONTIN/EIN
ORGANIZATIONAce Greenberg
PERSONHarry Beller
PERSON
Mort Zuckerman
PERSON
Harvey Weinstein
PERSON
Bruce Wasserstein
PERSON