EFTA01413301Set 10
2012-07-3183p7,775w
were updated as per the PWM High Risk Country Circular. All high risk
country alerts (RACS3, RACS3Neg, RACS4, and RACS4Neg) were adjusted
accordingly. On July 31, 2012, RACS3 and RACS3Neg ... alerts were updated to
include country code CW Curacao, Netherlands Antilles. The Netherlands
Antilles is considered a moderate high risk country. The International
Organization of Standardization (ISO) added the code ... been a pattern of cash deposit activity throughout
a one month period.
Only three alerts have been generated since January 1, 2011.
ANALYTICAL PROCESS
A review of all cash deposits
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01413301.pdf
EFTA01415287Set 10
2016-10-134p602w
AMLKYC
Thursday, October 13, 2016 3:40 PM
Cynthia Rodriguez; PWMUS AMLKYC
CLEARED: RDC alert_Jeffrey Epstein and PCR alert_Jeffrey Epstein [I]
Chip Packard Approval - Jeffrey Epstein.pdf; CLEARED_Jeffrey ... Epstein _RDC
Alert,Jeffrey
Epstein PCR Aler.pdf
Blue Category
Classification: For internal use only
Hello Cynthia,
AML Compliance has reviewed the one PCR alert and three RDC alerts and
generated ... Jeffrey Epstein, Grantor of the
Butterfly Trust, client of the Private Bank.
RDC Alerts:
Alert #1:
The subject of the alert is a positive match the grantor. AML Compliance
previously
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01415287.pdf
EFTA01299252Set 10
2016-10-123p560w
October 12, 2016 2:15 PM
To: Cynthia Rodriguez; PWMUS AMLKYC
Subject: CLEARED: RDC ALERT - Richard Kahn [I)
Classification: For Internal use only
Hello Cynthia,
AML Compliance has reviewed ... four RDC alerts generated for Richard Kahn, beneficiary of the Butterfly Trust, client.
Alert #1:
• The subject of the alert resides in PA.
• The beneficiary resides ... address history in PA according to LexisNexis.
AML Compliance clears this alert from an AML perspective as the location of the beneficiary does not match that of the
alert subject
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01299252.pdf
EFTA01413503Set 10
2012-06-0819p2,104w
Annual AML Monitoring Program Review
For the Private Bank, new alert parameters in 9.1 have caused significant
spike in alerts. For example, repetitive alerts were generating
approximately 116 alerts ... month. In 9.1 this has spike to approximately
238 per month. Proposal to analyze alerts to consider recalibrating or
adding more accounts on the exclude list.
Recommend changing the review ... recalibration schedule to an ongoing
process. A set of alerts will be reviewed every 2 months. There are 6
groups of alerts — Cash, Dormant, HubSpoke, Repetitive, High Risk Country
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01413503.pdf
EFTA01299233Set 10
2013-05-283p542w
internal use only
Hi Amanda,
AML Compliance has reviewed the RDC and PCR alerts dated 5/28/2013 pertaining to our prospective
client, Jeffrey Epstein. The RDC Alerts are positive matches ... pertains to negative
information based on reputation. However, AML Compliance clears these alerts based on the attached
email approval from Chip Packard with the support of senior management ... reputational and
legal perspective to onboard the prospective client, Jeffrey Epstein.
The two PCR alerts involve a Jeffrey S Epstein that lives in Massachusetts. Our prospective client has a
different
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01299233.pdf
EFTA01299236Set 10
2013-05-283p543w
internal use only
Hi Amanda,
AML Compliance has reviewed the RDC and PCR alerts dated 5/28/2013 pertaining to our prospective
client, Jeffrey Epstein. The RDC Alerts are positive matches ... pertains to negative
information based on reputation. However, AML Compliance clears these alerts based on the attached
email approval from Chip Packard with the support of senior management ... reputational and
legal perspective to onboard the prospective client, Jeffrey Epstein.
The two PCR alerts involve a Jeffrey S Epstein that lives in Massachusetts. Our prospective client has a
different
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01299236.pdf
EFTA01428439Set 10
2013-05-283p508w
internal use only
Hi Amanda,
AML Compliance has reviewed the RDC and PCR alerts dated 5/28/2013 pertaining to our prospective
client, Jeffrey Epstein. The RDC Alerts are positive matches ... pertains to nega
tive
information based on reputation. However, AML Compliance clears these alerts based on the attached
email approval from Chip Packard with the support of senior management ... reputational and
legal perspective to onboard the prospective client, Jeffrey Epstein.
The two PCR alerts involve a Jeffrey S Epstein that lives in Massachusetts. Our prospective client
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01428439.pdf
EFTA01433697Set 10
2016-12-2017p2,669w
Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE
TRUST, Account# N4G024943, Alert# SAM1788880 [I]
From: Stewart Oldfield ‹ >
Date: Tue, 20 Dec 2016 10:34:16 -0500
To: Vahe ... Oldfield
Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE
TRUST, Account# N4G024943, Alert# SAM1788880 [I]
Classification: For internal use only
Will defer to you on this in terms ... Inquiries
Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE
TRUST, Account# N4G024943, Alert# SAM1788880 [I]
EFTA01433697
Classification: For internal use only
Good Morning:
Please find out where these
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01433697.pdf
EFTA01419393Set 10
2014-12-2332p3,569w
Financial LLC [I]
Classification: For internal use only
Hi Dmitri,
We have got the alert review for the RDC alert received on Richard Kahn.
During the alert review, we have ... found that these alerts are false positive.
Please refer to the below mail with regard to Alert review for your
reference.
Please let us know, if anything is required from ... package for the RID : ONB-120902 LKYCUS-3443 Party name :
Southern Financial LLC - RDC alert Review - Very Urgent [I]
Classification: For internal use only
Hello All,
Please find the details
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01419393.pdf
EFTA01409618Set 10
2016-12-2018p2,761w
Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE
TRUST, Account# Alert# SAM1788880 [I]
From: Zbynek Kozelsky <
Date: Tue, 20 Dec 2016 10:31:40 -0500
To: Amlcompliance Inquiries ... Amlcompliance Inquiries
Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE
TRUST, Account# Alert# SAM1788880 [I]
Classification: For internal use only
Good Morning:
Please find out where these funds ... Cherie Quigley <
Subject: RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE
TRUST, Account# , Alert# SAM1788880 [I]
Classification: For internal use only
Client is a billionaire. It's not like
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01409618.pdf