Epstein Secrets

plicable for operating entitles • Yes W No Is the individual a Politically Exposed Person (PEP)?(if Ve4 desoibe) Connection with Prince Andrew and Bill Clinton 0 Yes O No To the best of your knowledge, is the Individual related to an employee of the DB group7(, 1 Family or Fnendsivp, descfibe) N/A O Fam

desoibe) Connection with Prince Andrew and Bill Clinton 0 Yes O No To the best of your knowledge, is t

t 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 Cottrell Gwen Hill (Signature) Richard Cottrell Gwen Hill 10/2

ble fox operating entities O Yes IgNo Is the individual a Politically Exposed Person (PEP)?(/ Yes, rfescrkie) Connection with Prince Andrew and BM Clinton 2 yes O No To the bet of your knowledge, is the individual related to an employee of the CB group?(tie EOM* or Fnivddip, &scree) WA O Family O

Source of Wealth (SOW) Industry: Financial Management • PEP/RCA: Jeffrey Epstein, UBO & SOW, is considered an RCA based on Ns dose relationship with Bill Clinton and Prince Andrew. • Media: Negative media related to Jeffrey Epstein has been previously reviewed and escalated for reputatienal risk ce cenms.

art Oldneld (Signature) Stumert Oklfleld 10/15/2018 Office Director/Business Head: Andrew F Gallivan (Signature) Andrew F Gallvan 10/15/2018 Regional Office greeter: (Signature) AIL Business Risk: (Signature) MIL Compliance: Thane miiiigan (Swann) Jeana Milligan 11/14/2018 li LATAM/INTERNATIONAL

pplicable for operating entitles ri Yes 2 Pb " Is the indMdual a Politically Exposed Person (PEP)?(// Yes, *sate) Correction with Prince Andrew and Bill Clinton 2 yes O Pb To the best of your kncmledge, is the individual related to an empkryee of the 08 group?(d Family oneriendS4), describe) N/A O Family

s, *sate) Correction with Prince Andrew and Bill Clinton 2 yes O Pb To the best of your kncmledge, is t

rt 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 Cottrell Gwen Hill (Signature) Richard Cottrell Gwen Hal 10/26/

W venfication was obtained. Negative Media & PEP: There is some negative media against Mr Epstein and he is also maintains a dose relationship with Bill Ointon and Prince Andrew. Please see risk calculator for more information. Appropriate approval was obtained. • Ow review did not identify any red flags a

stewart oldf,eld (Signature) stewat cedfield 7/5/2017 Office Director/Busness Head: Andrew F Gatvan (Signature) Andrew F Gallivan 7/6/2017 Regional Office brector: (Signature) AML Business Risk: (&g nature) AML Compkance: D. man!ey obo Kshttii Golan, Yoonsun Chung (*nature) D. Manley obo Ks fo

to which Section 10 directly applies—it does not perforce apply when the Board specifies affirmative requirements via rulemaking under Section 6. See Clifton v. FEC, 114 F.3d 1309, 1312 (1st Cir. 1997) (“Agencies are often allowed through rulemaking to regulate beyond the express substantive directives of

becomes available in that language. With respect to employees who are vision-impaired or those who are illiterate, employers may consult the Board’s Regional Office on a case-by- case basis for guidance on appropriate methods of providing the required notice, including by audio recording. d. Electronic Posting

er, 879 F.2d 266 (7th Cir. 1989); Kephart v. Inst. Gas Tech., 581 F.2d 1287, 1289 (7th Cir. 1978); Beshears v. Asbill, 930 F.2d 1348 (8th Cir. 1991); McClinton v. Alabama By- Prods. Corp., 743 F.2d 1483 (11th Cir. 1984); see also Henchy v. City of Absecon, 148 F. Supp. 2d 435, 439 (D. N.J. 2001); Kamens v. S