EFTA01388176.txt Text dataset_10 View on DOJ

Illegal Activity

suspicious

Blackmail

none

Date

2018-07-31

Document Type

Model

gemini-2.0-flash-001

Processed

2026-02-07T18:42

Summary

This email discusses a periodic review of high-risk accounts, specifically the Butterfly Trust (linked to Jeffrey Epstein) and Neptune LLC, raising questions about the trust's classification, the accuracy of a Volcker Questionnaire, and the addition of a new manager to Neptune LLC without proper KYC review. The email requests clarification and confirmation on these issues to ensure compliance.

Metadata

Subject: 2018 Periodic Review of High Risked Accounts
Sender: Vijay-A Sawant
Recipients: Bradley Gillin, Stewart Oldfield
Document ID: GCIS#486426, GCIS#487264, KYC Case#01790739
Date: 2018-07-31

Illegal Activity

Severity: suspicious
Description: The document raises questions about the nature of the Butterfly Trust and the relationship between the grantor and the UBOs, which could potentially be related to tax evasion or other financial crimes. The addition of Richard Kahn as manager of Neptune LLC without proper KYC review is also suspicious.
Content Type: first_hand

Relationships 7

Entity 1	Relationship	Entity 2	Description
Butterfly Trust	Grantor	Jeffrey Epstein	Jeffrey Epstein is the Grantor of the Butterfly Trust.
Butterfly Trust	Trustee	Harry Beller	Harry Beller is a Trustee of the Butterfly Trust.
Butterfly Trust	Trustee	Erika Kellerhals	Erika Kellerhals is a Trustee of the Butterfly Trust.
Butterfly Trust	UBO	Darren Indyke	Darren Indyke is a UBO of the Butterfly Trust.
Butterfly Trust	UBO	Karyna Shullak	Karyna Shullak is a UBO of the Butterfly Trust.
Butterfly Trust	UBO	Richard Kahn	Richard Kahn is a UBO of the Butterfly Trust.
Neptune LLC	Manager	Richard Kahn	Richard Kahn has been added as manager of Neptune LLC.

Notable Quotes 2

Kindly confirm if this is a Personal Trust and NOT Corporate Trust? After reviewing the trust agreement, we noticed that the UBO's seem not related to the grantor.

Volcker Questionnaire completed reflects this trust as a "Family Trust" but this seems inaccurate. All UBO's have different surnames and some even different nationalities. Please advise if ok to accept?

Red Flags 2

Discrepancy between the Volcker Questionnaire and the actual composition of the Butterfly Trust's UBOs.
Richard Kahn being added as manager of Neptune LLC without being added as an RP in the previously approved KYC Case.

Public Knowledge

Context: The document involves Jeffrey Epstein and raises questions about the structure and purpose of the Butterfly Trust, which could be of interest to the media.
Media Worthy: Yes

Legal Compliance

Potential misclassification of the Butterfly Trust as a 'Family Trust' when UBOs have different surnames and nationalities.
Need for CDD form if Butterfly Trust is deemed a Corporate Trust.

Raw Analysis JSON click to expand

Themes

Financial transactions/money flowBusiness dealingsCommunications/correspondence

People 10

Vijay Sawant Bradley Gillin Stewart Oldfield Mayur Rathod Jeffrey Epstein Harry Beller Erika Kellerhals Darren Indyke Karyna Shullak Richard Kahn

Organizations 6

Butterfly TrustNeptune LLCDeutsche CM Centre Private LimitedDeutsche Bank GroupWealth ManagementSOUTHERN FINANCIAL RELATIONSHIP

Locations 3

MumbaiIndiaDB Centre Mumbai, Nirton Knowledge Park, Western Express Highway Goregaon East, Mumbai - 400063, India

Financial Entities 1

Deutsche Bank

Text Analysis

Tone: Professional
Purpose: To conduct a periodic review of high-risk accounts (Butterfly Trust and Neptune LLC) and to request confirmation and clarification on certain aspects of the accounts and their related parties.
Significance: The document highlights potential discrepancies in the account information and raises questions about the nature of the Butterfly Trust (personal vs. corporate) and the accuracy of the Volcker Questionnaire. It also indicates that Richard Kahn was added as manager of Neptune LLC without being added as a related party in the KYC case.

File Info

File Name: EFTA01388176.txt
Dataset: dataset_10
Type: Text
Model: gemini-2.0-flash-001
Processed: 2026-02-07T18:42:06.492281
DOJ Source: View on DOJ