Epstein Files Search

EFTA01399077Set 10

2018-01-0370p4,378w

approval after obtaining written approval from Regional Business Head. BM to obtain and attach EMEA Legal and Compliance(2) approval prior to approving non-target lead request. BS0 to ensure ... fields for EEA clients/accounts. (2)The below information must be provided as part of EMEA Legal and Compliance approval request: Domicile of client / entity / Business Owner / decision takers ... Control Details 2. New Accounts BM to obtain/coordinate approvals from Regional Business Head and EMEA Legal and Compliance(1). Sign and return the EEA Client Declaration form and email approvals

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399077.pdf

EFTA01399167Set 10

3p417w

Worksheet 3 has the mismatches and related comments. Attachment: Mismatch EEA Report Evidence # 3: EMEA Legal & Compliance approvals Description: selected a sample of EEA lead/prospects and clients for which ... compliance facilitated approvals from EMEA Legal & Compliance. The following testing was performed for the selected record: Confirm if KYC was approved Confirm if EEA fields were updated in dbForce Confirm

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399167.pdf

EFTA01399150Set 10

5p1,301w

approvals prior to approving in DB Force: Regional Business Head or their delegate EMEA legal AND compliance (US Compliance will be responsible for obtaining these approvals) If the non-target

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399150.pdf

EFTA01356557Set 10

1p504w

rational to be retained. • New accounts: i. Implemented approval process for new EEA clients/accounts (EMEA legal & compliance approvals — see attached evidence for operational effectiveness). it Implemented reverse solicitation controls

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356557.pdf

EFTA01356570Set 10

1p522w

prior to approving in DB Force: o Regional Business Head or their delegate o EMEA legal AND compliance (US Compliance will be responsible for obtaining these approvals

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356570.pdf

EFTA01399164Set 10

1p338w

target coverage (use non-target paper form) 10 Yes Was the client approved by EMEA legal & compliance 11 Yes Is the "Banker" attestation form confirming that reverse solicitation

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399164.pdf