EFTA01412389.pdf

MASTER PROFILE Legal Name Summary RDC Check Status Next Review Date CDD Entity Type Has RDC Screening been done? Deferral Flag Migration Date Entity/Legal Name KYCMode Not Alerted 20190503 Private Entity Yes No GMT Southern Financial, LLC Full Global Risk Southern Financial, LLC HIGH Master KYC Profile MASTER-57622 SRC Nexus No Last Review Date 03/05/2018 Entity Details Internal ID List Is Restricted Identifier SOUTHFIN LE Tax Details TaxID Type EIN Client Role List Client Role Underlying Principal Principal Page 1 Affirmation Status Name Internal Pending COB review - Paragon (PARAGON) DBForce Customer Number (DBFORCE CUSTOMER NUMBER) Name — OPENLINK Paragon (PARAGON) DBForce Customer Number EFTA01412389 (DBFORCE_CUSTOMER_NUMBER) Tax ID Country / ISO United States EFTA01412390 Address Details Street Address Line 3 Street Address Line 2 Street Address Line 1 6100 Red Hook Quarter B3 6100 Red Hook Quarter B3 6100 Red Hook Quarter B3 Alias Alias Party Name Southern Financial Llc External ID List Status State Street Address Line 4 Postal Code Country 00802 00802 00802 Virgin Islands, U.S. Virgin Islands, U.S. Virgin Islands, U.S. City St Thomas St Thomas St Thomas AddressType DOMICILE REGISTERED MAILING Next Renew Date Identifier 01/01/1970 29191984 Name AVOX (AVOX) Individual Details PEP Next Review Date Classifications EFTA01412391 Classification NAICS Code Classification NACE Code Classification NAICS Classification Bundesbank Sector Classification NACE Supranational Authority Central Clearing Party Classification SIC CFTC Interim Compliant Identifier (CICI) (CFTC INTERIM COMPLIANT IDENTIFIER CICI) Name - External AVOX (AVOX) Legal Entity Identifier (LEI) CFTC Interim Compliant Identifier (CICI) (CFTC INTERIM COMPLIANT IDENTIFIER CICI) 01/01/1970 - 522298 All Other Nondepository Credit Intermediation Financial auxiliaries Activities auxiliary to financial intermediation n.e.c. N N Miscellaneous Business Credit Institutions Page 2 EFTA01412392 Tri party Agent N Classification SIC Code Classification Bundesbank Sector Code Business Relationship Status Inactive Inactive Active Inactive Adoption Location United Kingdom United States United Kingdom United States Related Parties Folder ID MASTER-57623 MASTER-57623 Entity Information Eligible For Deferral Yes No Deferral Flag No Deferral Expiration Date Migration Date Deferral Activation Date Last Review Date Next Review Date KYC Status 01/01/197003/09/201801/01/19702018051720190517Completed 01/01/197001/01/197001/01/19702018051720190517Completed 01/01/197001/01/197001/01/19702015011620160116Completed Conditional Approval Status EFTA01412393 Adoption Location DE GB US Calculation Reason Global Standard Risk Rating Eligible for Deferral expiration Date Conditional Approval Expiry Date BR Name Southern Financial, LLC_Markets_NSP Southern Financial, LLC_Markets_NSP Southern Financial LLC_Markets_NSP Southern Financial, Llc AC ORDER Markets— NSP Business Unit Name Markets Markets Markets Markets Adoption Entity View BR DB AG (London) 1007494283 DBSI 1007494283 DB AG (London) 1010240825 DBSI 1014449003 Participant Role Adoption Date Principal Principal Agent Principal 26/07/2017 20/01/2015 15/07/2016 08/12/2017 6159 EFTA01412394 S126 Entity ID Entity Type 1007493407 1007493407 Ultimate Beneficiary Owners Legal Representative Entity Name Jeffrey Edward Epstein Jeffrey Edward Epstein AFC Escalation High 03/09/201901/01/1970 HIGH 01/01/197001/01/1970 true High 01/01/197001/01/1970 true Page 3 EFTA01412395 Global CDD Entity Capacity Client Role Contracting Party Business Relationships: Is the entity that is being onboarded, contractually engaged by DB to develop investment business relationships or to introduce / procure business transactions e.g. a business finder / arranger / introducer / consultant / intermediary etc? Entity Ownership Provide document for evidence of the entity's Ownership Structure Provide document for evidence of the entity's UBO relationships Risk Factors Have you come across any other reason for escalation to AFC Compliance? KYC Review Are you going to complete a full CDD/KYC Review for this Entity? CDD KYC Type Select the applicable Client KYC Type: Organization Formation Provide document for evidence of the entity's Legal Name Provide document for evidence of the entity's formation and Legal Form Country Risk associated with the Registered address of the entity: Country Of Registration Virgin Islands, U.S. Provide document for evidence of the entity's Registered Address Country Risk associated with the Domicile Address of the entity: Country Level 2 ORBIS.pdf ORBIS.pdf Private Entity Yes No Multiple Southern Financial Operating Agreement.pdf Principal No Country Level 2 ORBIS.pdf Country Of Operation Virgin Islands, U.S. During the course of due diligence was any nexus to a Special Risk Country found? Source Of Wealth Have you identified the source of wealth for all UBOs who hold greater than or equal to 25% (in case of CDD) or 10% (in case of EDD) in the Ownership? Yes Page 4 No EFTA01412396 Please provide additional explanation: Jeffery Epstein began his financial career in 1976 as an options trader at Bear Stearns and became a partner in 1980. In 1982, Epstein founded his own financial management firm, J. Epstein & Co., managing the assets of clients with more than a billion in net worth. In 1996, Epstein changed the name of his firm to The Financial Trust Company and based it on the island of St. Thomas in the US Virgin Islands, which merged into Southern Financial LLC. All of his clients were anonymous except for the very wealthy businessman Leslie Wexner. His wealth has come from his days at Bear Stearns and his financial management firms. Due Diligence Level Specifiy the level of due diligence being performed EDD Summary Is EDD Applicable? Have Source of Funds been verified? What verification has been performed on the Source of Funds explanation received Enhanced Due Diligence Yes Yes The annual report provides the evidence for SOF for Southern Financial LLC What evidence has been obtained which supports the Source of Funds activity? The annual report provides the evidence for SOF for Southern Financial LLC Does the evidence obtained satisfy reliability and independence criteria?- (Source of Funds) Yes Have Source of Wealth been verified? What verification has been performed on the Source of Wealth explanation received? Yes o Jeffery Epstein began his financial career in 1976 as an options trader at Bear Stearns and became a partner in 1980. In 1982, Epstein founded his own financial management firm, J. Epstein & Co., managing the assets of clients with more than a billion in net worth. In 1996, Epstein changed the name of his firm to The Financial Trust Company and based it on the island of St. Thomas in the US Virgin Islands, which merged into Southern Financial LLC. All of his clients were anonymous except for the very wealthy businessman Leslie Wexner. His wealth has come from his days at Bear Stearns and his financial management firms. What evidence has been obtained which supports the Source of Wealth Business Activity? Does the evidence obtained satisfy reliability and independence criteria? Confirm all UBO(s) with an ownership of 10% or more (directly or indirectly) been identified & verified and the requirements obtained? EFTA01412397 Internet Searches / NLS Did the internet searches /NLS uncover any adverse media? Please provide detail Has the use of a External vendors been used as directed by the Business? Please provide a detailed explanation Has the EDD Memo been completed and appended to the KYC file? Bearer Shares Are you aware of the presence of Bearer Shares? Nature of Business Page 5 No SCR confirmation Yes Yes Yes Yes RDC Alert on the sole owner of Southern Financial. No N/A. Yes EFTA01412398 Nace Code Nace Description Is DB facing a shell bank? Is this client involved in any of the following Industries: Activities auxiliary to financial intermediation n.e.c. No No Is the entity a Private Investment Vehicle i.e. a private investment company, foundation or trust set up for/on behalf of a high net worth individual(s)/family? No During the course of due diligence has any nexus to the Credit Directives policy been discovered? No Ownership Ownership Ownership Structure ActualOwnershipPercentage Legal Name 100.00 Beneficial Individuals PEPStatusDescActualOwnershipPercentage Is UBO First Name if true, page is not involved in database operations 100.00 Yes Jeffreytrue DOMICILEIndividual Individual is neither a PEP nor related/close associate of a PEP Screening Results Edward United States falseActive Epstein Jeffrey Edward EFTA01412399 Epstein UBO Selected 7 ParentOf Address Type 17081 Southern Financial, LLC if true, page is not involved in database operations DOMICILEtrue 1 United States false Indiv CountryLevel Is PEP First Name Party ID PCRHitDetect Country Of Birth PartyTmpFlagEntityLevel Address Type EntityTypels PEP First Name BusinessConclusionEntity ID Date of Birth Is PEP Old Nationality Tmp Flag Status Last Name EFTA01412400 BusinessInterest0fPEP Page 6 EFTA01412401 RDC Check Status Alerted, NonAFC Local Legal Name Jeffrey Edward Epstein Related Parties Related Parties Related Parties Nature of Lexis/Nexis Local Legal Name Jeffrey Edward Epstein RDC Screened Address Type Yes Country Level PEP Status Nationality DOMICILE]. Individual is neither a PEP nor related/close associate of a PEP Classifications Wholesale Test Is this entity eligible for the Australian Wholesale Test? PCR PCR Has a PCR hit been detected? Document ID that evidences the PCR check result: Do you want to perform PCR for additional parties? Additional Due Diligence Has any additional due diligence been performed? PEP Does the Legal Representatives have a PEP status? Does the UBO have a PEP status? EFTA01412402 Negative Information Page 7 No No No No Hit LINK-ATTACHMENT DB-FW-CAR-ONB-WORK GKYC-65841!20141204T210725.071 GMT No No Lexis/Nexis Status Relationship to CP US Legal Representative CRDS ID Designation / Position Registered Country 1007493407Director US EntityKYCMode Biz PCR Comments Nature of Lexis/Nexis Validator Action RDC Screened if true, page is not PCRStatusDesc involved in database operations Yes true DOMICILEIndividual Edward Address Type EntityType Biz PCR Response First Name EFTA01412403 Lexis/Nexis Status Nature of PCR Hit Norkom Result Validator Response Entity ID PCR Hit Tmp Flag 1087493487 false Indiv EFTA01412404 To your knowledge, are you aware of any material negative information (from PCR or any other source) about the entity, and/or its UBO's and Legal Representatives, which could pose a reputational risk to DB? Screening Results Screening Results Document that evidences the NLS check result: Is there a Hit(s) from Name List Screening? IsNextandLastReviewDatesRecalculated To your knowledge, are you aware of any material negative information (from NLS or any other source) about the entity,and/or its UBO's and Legal Representatives, which could pose a reputational risk to DB? Has any additional due diligence been performed? Screening Confirmations Screening Confirmations IsNextandLastReviewDatesRecalculated No LINK-ATTACHMENT DB-FW-CAR-ONB-WORK GKYC-65841!20141204T210725.071 GMT No Hit No No No No Page 8 EFTA01412405 Global Risk Assessment Risk Assessment Global CRRE Risk Score 13 Global CRRE Risk Level HIGH Special Risk Factors - Item New Response UBO PEP LR PEP Adverse Media Bearer Shares Complex Structure Link to Special Risk Country (CRRE) Nexus to Special Risk Country (Global Due Diligence) Link to Special Risk Industry (CRRE) Link to Special Risk Entity Intermediaries Any other reason for escalation to AFC? Downstream Correspondent Banking Activity No No No No No No N/A No No No No N/A Yes Previous Response Pillar Summary - Item COUNTRY ENTITY INDUSTRY PRODUCT Override Risk Rating Override Risk Rating ? Override KYC Next Review Date Overriding KYC Next Review Date is to be used in exceptional circumstances only. It should not be used as a substitute for answering the KYC questions correctly to derive the appropriate KYC Next Review Date. No Global Risk MEDIUM MEDIUM HIGH EFTA01412406 HIGH Global Score 3 2 5 3 No Page 9 EFTA01412407 UK Risk Assessment Risk Assessment Global CRRE Risk Score 13 Global CRRE Risk Level HIGH RACS Risk Rating Local Final Risk HIGH Global Final Risk HIGH Special Risk Factors - Item New Response UBO PEP LR PEP Adverse Media Bearer Shares Complex Structure Link to Special Risk Country (CRRE) Nexus to Special Risk Country (Global Due Diligence) Link to Special Risk Industry (CRRE) Link to Special Risk Entity Intermediaries Any other reason for escalation to AFC? Downstream Correspondent Banking Activity No No No No No No N/A No No No No No N/A Yes Yes Previous Response Pillar Summary - Item COUNTRY ENTITY INDUSTRY PRODUCT Override Risk Rating Override Risk Rating ? Override KYC Next Review Date Page 10 EFTA01412408 Local Score 3 2 5 3 Local Risk MEDIUM MEDIUM HIGH HIGH Global Risk MEDIUM MEDIUM HIGH HIGH Global Score 3 2 5 3 No EFTA01412409 Overriding KYC Next Review Date is to be used in exceptional circumstances only. It should not be used as a substitute for answering the KYC questions correctly to derive the appropriate KYC Next Review Date. No Page 11 EFTA01412410 US Risk Assessment Risk Assessment Is the entity registered or domiciled in a Level 1,2,3,4 Country: Is the entity involved in a high risk industry? Is a UBO of the entity a national of a Level 4 country and/or domiciled in a Level 4 country? If a natural person facing DB as a direct client - are they a PEP (determined from PCR or any other source)? Is a UBO of the entity a PEP? Is a legal representative (control person) of the entity a PEP (determined from PCR or any other source)? Is 10% or greater of the ownership held in bearer form? (not applicable if the bearer shares are traded on a CB&S and GTB Recognised Exchange) To your knowledge, are you aware of any material negative information (from PCR or any other source) about the entity, and/or its UBO's and Legal Representatives, which could pose a reputational risk to DB? If DB are facing a Collective Investment Scheme (Both open-ended and closed end funds) - does a natural person own greater than 25% of the investment (directly or indirectly) in the CIS? Is the entity a Private Investment Vehicle i.e. a private investment company, foundation or trust set up for/on behalf of a high net worth individual(s)/family? Is the entity that is being onboarded, contractually engaged by DB to develop investment business relationships or to introduce / procure business transactions e.g. a business finder / arranger / introducer / consultant / intermediary etc? Have you come across any other reason for escalation to AML Compliance? Is an account being opened for a foreign financial institution* (liFFI") registered and/or domiciled in either a Level 3 or 4 Country ? * Foreign financial institutions as defined within Section 312 of the USA PATRIOT Act are Non- U.S banks, broker dealers, futures commission merchants, Introducing brokers in commodities, mutual funds, money transmitters or currency exchangers and private banking accounts. Total Risk: Override Risk Rating Override Risk Rating ?Overriding Risk Rating is to be in exceptional circumstances only. It should not be as a substitute for answering the KYC questions correctly to derive the appropriate Risk Rating. Override KYC Next Review Date Override KYC Next Review Date ?Overriding KYC Next Review Date is to be used in exceptional circumstances only. It should not be used as a substitute for answering the KYC questions correctly to derive the appropriate KYC Next Review Date. No No 2 No No N/A EFTA01412411 No No No No N/A Yes No No No High Page 12 EFTA01412412 UK CDD Escalation Have you come across any other reason for escalation to AFC Compliance? KYC Review Are you going to complete a full CDD/KYC Review for this Entity? Yes No Page 13 EFTA01412413 USA CDD US Primary Business Function Please select the US Primary Business Function Qualified Institutional Buyer Is the client a Qualified Institutional Buyer ? UBO Requirements Is the pension fund ERISA qualified ?If it is ERISA qualified then there are no UBO requirements Is the entity a foreign bank or a level III FFI ? USA Patriot Act Requirements Is the client a non-US bank ? Has the Disclosure Document be sent to client Date Sent Addressee Has the Disclosure Document be sent to client.**This is only applicable to foreign banks RDC Has RDC screening been done ? RDC Check Status Do you want to perform RDC for additional parties ? Related Party RDC: RDC Check Status Alerted, Non-AFC RDCAlertList RDCEventCategoriesRDCCheckStatus AST,CON,PRJ,FRD, IMP,IPR,OBS,ORG, SEX,TAX,TFT Alert ID if true, page is not EventCategoryRDCLegalNameSubCategory involved in database operations Alerted, Non-AFC 33455 Jeffrey Edward Epstein true N DB27000P ACC,APL,CHG,CVT,IND, PLE,PRB,SJT,SET,TRL Page 14 PortfolioFlagFirmNo RDCSubEventCategories Yes Not Alerted Yes EFTA01412414 No No No Private investment vehicle No Yes 20141126 Physical CIP Mail sent No Legal Name Relationship to CP Jeffrey Edward Epstein Ultimate Beneficial Owner EFTA01412415 FINRA Is the client FINRA 2111 suitable? FINRA 2111 is not applicable for all products, please refer to Key Operating Procedures Market Participant Identifier Is the client a broker/dealer Escalation Have you come across any other reason for escalation to AML Compliance? Enhanced Due Diligence Is Enhanced Due Diligence required ? What type of account is the client opening with CIB? Who is their Registered Supervisor? What is the client's source of funds? Yes Equities - Custody/Margin Courteney Fornal 100% money of Jeff Epstein from his work in the financial industry. Source of funds for Southern Financial LLC is that of Jeffrey Epstein. Epstein began his financial career in 1976 as an options trader at Bear Stearns and became a partner in 1980. In 1982, Epstein founded his own financial management firm, J. Epstein & Co., managing the assets of clients with more than a billion in net worth. In 1996, Epstein changed the name of his firm to The Financial Trust Company and based it on the island of St. Thomas in the US Virgin Islands which merged into Southern Financial LLC. All of his clients were anonymous except for the very wealthy businessman Leslie Wexner. His wealth has come from his days at Bear Stearns and his financial management firms What is the client's line of business? What is their expected activity? Foreign Financial Institution Is an account being opened for a foreign financial institution* (liFFI") registered and/or domiciled in either a Level 3 or 4 Country ? * Foreign financial institutions as defined within Section 312 of the USA PATRIOT Act are Non- U.S banks, broker dealers, futures commission merchants, Introducing brokers in commodities, mutual funds, money transmitters or currency exchangers and private banking accounts. AFC Escalation Form For United Kingdom General Information Entity Legal Name: KYC Type Nace Code Nace Description Global risk rating Local risk rating Entity Role Page 15 No Private Investor EFTA01412416 Flow trading No N/A No Southern Financial, LLC Private Entity Activities auxiliary to financial intermediation n.e.c. HIGH HIGH Contracting Party EFTA01412417 Due Diligence Why is AFC Assignment required? (Tick as many as required) Conditional Approval false SRC Nexus: Name List Screening Screening system Google false Volcker Super 23A Restricted list false Please provide details Adoption Information Initiator Location of Initiator Request Type Business Sponsors & Approvers Business Approver Joe Aglione Joe Aglione Joe Aglione Adoption Entity Product DB AG (London) Business Sponsor BA Location OTC Derivatives (Rates) Matthew OConnor DB AG (London) Commodities DB AG (London) FX Options DB AG (London) FX Cash Martin Zeman Joe Aglione Xavier Avila Xavier Avila AFC AFC Comments View of the Business Business Recommendation Page 16 System Approval NOT Product Extension John Kennedy Jatin Bindal John Kennedy John Kennedy DB AG (London) Convertible Bonds Martin Zeman DB AG (London) Fixed Income DB AG (London) GED EFTA01412418 DB AG (London) Global Credit Derivatives Martin Zeman Martin Zeman USA USA USA USA Christopher Hatch USA USA USA Business Unit Markets Markets Markets Markets Markets Markets Markets Markets USA USA USA BS Location Adoption Location United Kingdom United Kingdom United Kingdom United Kingdom United Kingdom United Kingdom United Kingdom United Kingdom AFC Lexis Nexis false Sanction lists false CDD Gateway false PCR Norkom false negative list of rejected EFTA01412419 clients false FircoSoft RDC Yahoo true false false Internal Lists false Target lists false Embargo lists false Other false Searches ran with FircoSoft Country Risk false Source Of Funds false Other ML Factors have been identified false Material Negative Information false Change in risk rating false Sanctions & Embargoes false PEP Nexus false Bearer Shares false Consultation SourceOfWealthAFC false false Industry EFTA01412420 Risk false Product Risk false No Yes Jesse-3 Cruz USA Product Extension (PE) Continue the relationship EFTA01412421 Reason for Recommendation Product extension but past NRD Mitigating Factors Documents Documents Entity Name Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Status A A A A EFTA01412422 A A A A A A A A A Document Type Financial Statement Account Opening Checklist Operating Agreement Operating Agreement W-9 (December 2014) IRS LDD Checklist Operating Agreement cRDS ID Status 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified KYC Summary 1007406812Verified Operating Agreement W-9 (December 2014) W-9 (December 2014) CRS LDD Checklist CRS LDD Checklist 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified Account EFTA01412423 X Reference NA Document Classification Classification Documents Onboarding Documents Onboarding Documents Onboarding Documents Classification Documents Classification Documents Onboarding Documents Onboarding Documents Onboarding Documents Classification Documents Classification Documents Classification Documents Classification Documents Uploaded By File Name Southern Trust Company Inc. Financials June 2017.pdf soumya.devadiga@db.comONB-1135648 Check list.xlsx Southern Financial Operating Agreement.pdf Southern Financial NAO Docs ALL.pdf TAX W9 PADD Southern Financial, LLC UP 1007406812_20171120.pdf LDD Checklist. df Southern Financial Operating Agreement.pdf SOFL_ LLC_Documents.pdf Southern Financial Operating Agreement.pdf W9 signed 2017 11 20.pdf EFTA01412424 Tax W9 signed 1007406812 2017 11 20.pdf CRS Validation Check List.pdf CRS Validation Check List.pdf Page 17 EFTA01412425 Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC EFTA01412426 Southern Financial, LLC A A A A A A A A A A A A A A A A A A ISDA Uncleared Margin SelfDisclosure Letter Account Opening Checklist PCR check Evidence PCR check Evidence PCR check Evidence Lexis/Nexis Results Correspondence with Client Correspondence with Client Volcker Super 23A Screening Result PCR check Evidence Aminet Screenshot Commercial / Business Registry Extract Correspondence EFTA01412427 with Client PCR check Evidence Financial Statement Aminet Screenshot Volcker Super 23A Screening Result Financial Statement 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified Classification Documents 1007406812Proposed 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified 1007406812Verified Onboarding Documents KYC Documents KYC Documents KYC Documents KYC Documents KYC Documents KYC Documents KYC Documents KYC Documents KYC EFTA01412428 Documents KYC Documents KYC Documents KYC Documents KYC Documents KYC Documents KYC Documents KYC Documents UM Dummy Doc. df Checklist 1.xlsx NLS - LR's.pdf NLS - Alert - Darren K. Indyke.pdf NLS - IBO.pdf Lexis Nexis.pdf SCR Confirm on NOB.pdf W9 signed 2017 11 20.pdf VOLCKER UPDATED 12-14-2017.pdf PCR.pdf AMINET.pdf ORBIS. df SCR Confirm on all docs and info.pdf NLS.pdf Southern Financial LLC Financials June 2017.pdf Aminet.paf volcker non us.pdf Southern Trust Company_Inc._Financials June 2017. pdf Page 18 EFTA01412429 Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC Southern Financial, LLC A A A A A A A A A EFTA01412430 A A A A A Correspondence with Business Volcker Super 23A Screening Result Operating Agreement PCR check Evidence 1007406812Verified KYC Documents 1007406812Verified 1007406812Verified 1007406812Verified RDC Results 1007406812Verified RDC Results 1007406812Verified RDC Results 1007406812Verified RDC Results 1007406812Verified IRS LDD Checklist DF/EMIR Disclosure Correspondence LEI/CICI/GMEI 1007406812Verified EMIR Classification Correspondence Standard Settlement Instructions (SSI's) CFTC Classification 1007406812Verified 1007406812Proposed 1007406812Verified 1007406812Verified 1007406812Verified KYC Documents KYC Documents KYC Documents KYC EFTA01412431 Documents KYC Documents KYC Documents KYC Documents Classification Documents Classification Documents Classification Documents Classification Documents Fulfillment Documentation Classification Documents ACO.pdf volcker non us.pdf Southern Financial Operating Agreement.pdf NLS - Jeffrey_Epstein.pdf RDC7prif RDC_Alert_ - _Jeffrey_Epstein.pdf RDC - Jeffrey Epstein.pdf RDCIATert - S5unthern_Financial.pdf LDD Checkijit.pdf SCR Confirm on all docs and info.pdf LEI.pdf Southern Financial, LLC.pdf email from PWM regarding the SSI and callback.pdf Southern Financial, LLC -DF_CFTC clfn_CCE.JPG Requestor Name : Patrick Bradley Date : Fri Sep 20 17:02:25 BST 2019 Page 19 EFTA01412432