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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA00165646: Money Laundering and Beneficial Owner (DS9)

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This document is a Notice of Customer Identification Policy implementing anti-money laundering and terrorist financing requirements. It establishes procedures for obtaining photo identification from individuals and requires active involvement of asset management firms and clients in compliance efforts. The policy requires annual disclosure of information to beneficial owners, settlors, beneficiaries, and partners for tax compliance purposes.

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Excerpt 1
photo identification (Individuals). 3rd EU Notice Governmental rules have also broadened the scope of the Bank's obligations to aid in the fight against **money**
Excerpt 2
**laundering** and terrorist financing: these rules call for an active involvement of both asset management firms and their clients.
Excerpt 3
Also, enhanced enti-**money** **laundering** requirements require that should any of the above personal or institutional information change, our clients would

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