Epstein Index›Documents›EFTA01298715
⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01298715: Brennan, Client and Southern Trust (DS10)

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This document is a Deutsche Bank client compliance checklist addressing know-your-customer (KYC) and anti-money laundering (AML) requirements. It references Jeffrey Epstein as the sole owner of Southern Trust Company Inc and discusses client status changes between U.S. and non-U.S. persons. The document indicates compliance approvals needed for offshore accounts, reputational risk assessments including gambling nexus review, and client risk program forms. Zorro Management LLC is also mentioned as an entity requiring compliance documentation.

📋 Key Excerpts11

PersonKeyword
Excerpt 1
changing status to become a US person/US **client** changing status to become a Non -US person/POA or authorized signatory is non-U.S. but has @ U.S. address
Excerpt 2
) 0 AFC Reputational Risk Approval (gambling nexus) 0 AML Compliance & BRM Approval for US persons with an offshore PIC 0 **Client** and/or UBO from EU (refer
Excerpt 3
to Tab 3 - EU Country List) - add note to **client** profile 0 **Client** Risk Program (CRP) Form for all new loans (CRP forms are required at KYC stage because

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