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per the AML Procedures manual, certain clients are excluded from ACUs. An issue has been identified in dbforce where High Risk clients are given an ACU Auto Exemption for Retail Banking, however, per Policy, this exception does NOT apply to High Risk clients. Unfortunately, the code in dbforce exempting high risk clients with only
while the ACUs listed below don't appear as overdue, they must be completed by year end. Customer Name Customer # Relationship Primary Officer ACU Completed Date Butterfly Trust SOUTHERN FINANCIAL RELATIONSHIP Paul Morris EFTA01475244 The 2007 Jeffrey E. Epstein Insurance Trust #3 SOUTHERN FINANCIAL REL
per the AML Procedures manual, certain clients are excluded from ACUs. An issue has been identified in dbforce where High Risk clients are given an ACU Auto Exemption for Retail Banking, however, per Policy, this exception does NOT apply to High Risk clients. Unfortunately, the code in dbforce exempting high risk clients with only
while the ACUs listed below don't appear as overdue, they must be completed by year end. Customer Name Customer # Relationship Primary Officer ACU Completed Date Butterfly Trust SOUTHERN FINANCIAL RELATIONSHIP Paul Morris EFTA01475272 The 2007 Jeffrey E. Epstein Insurance Trust #3 SOUTHERN FINANCIAL REL
per the AML Procedures manual, certain clients are excluded from ACUs. An issue has been identified in dbforce where High Risk clients are given an ACU Auto Exemption for Retail Banking, however, per Policy, this exception does NOT apply to High Risk clients. Unfortunately, the code in dbforce exempting high risk clients with only
listed below don't appear as overdue, they must be completed by year end. Customer Name Customer # Relationship Primary Officer EFTA01475452 ACU Completed Date Butterfly Trust SOUTHERN FINANCIAL RELATIONSHIP Paul Morris The 2007 Jeffrey E. Epstein Insurance Trust #3 SOUTHERN FINANCIAL RELATIONSHIP Paul
per the AML Procedures manual, certain clients are excluded from ACUs. An issue has been identified in dbforce where High Risk clients are given an ACU Auto Exemption for Retail Banking, however, per Policy, this exception does NOT apply to High Risk clients. Unfortunately, the code in dbforce exempting high risk clients with only
while the ACUs listed below don't appear as overdue, they must be completed by year end. Customer Name Customer # Relationship Primary Officer ACU Completed Date Butterfly Trust SOUTHERN FINANCIAL RELATIONSHIP Paul Morris The 2007 Jeffrey E. Epstein Insurance Trust #3 SOUTHERN FINANCIAL RELATIONSHIP Paul
Entities connected to both ACU Auto Exemption for Retail Banking and ACU Completed Date

Paul Morris
PERSONAmanda Kirby
PERSONJj Litchford
PERSONDeutsche Asset & Wealth Management
ORGANIZATIONZorro Development Corp.
ORGANIZATIONNeptune
ORGANIZATIONHyperion Air
ORGANIZATION
Jeffrey Epstein
PERSONJeffrey E. Epstein Insurance Trust
PERSONAmanda
PERSONNew York Strategy Group
ORGANIZATION