Illegal Activity
suspicious
Blackmail
none
Date
2018-09-05
Document Type
email_chain
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:42
Summary
This email chain discusses the KYC review process for high-risk accounts at Deutsche Bank, specifically Butterfly Trust and Neptune, LLC, which are associated with Jeffrey Epstein. The emails highlight the need for accurate documentation and compliance with AML regulations, raising concerns about potential discrepancies and the nature of the relationships within these accounts.
Metadata
- Subject
- Re: 2018 Periodic Review of Hi h Risked Accounts , Butterfly Trust and Neptune, LLC under the SOUTHERN FINANCIAL RELATIONSHIP [I]
- Sender
- Stewart Oldfield
- Recipients
- Vijay-A Sawant, Richard Iarossi, Mayur Rathod, Bradley Gillin
- Document ID
- KYC Case#IIIIIIII
- Date
- 2018-09-05
Illegal Activity
- Severity
- suspicious
- Description
- The document discusses the KYC review of accounts associated with Jeffrey Epstein, including Butterfly Trust and Neptune LLC. While the document itself doesn't contain direct evidence of illegal activity, the association with Epstein raises concerns and warrants further investigation.
- Content Type
- first_hand
Evidence:
- The document references high-risk accounts associated with Jeffrey Epstein, which raises concerns given his history of illegal activities.
Relationships 9
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Stewart Oldfield | Work | Vijay-A Sawant | Stewart Oldfield is directing Vijay-A Sawant to complete KYC reviews for high-risk accounts. |
| Butterfly Trust | Grantor | Jeffrey Epstein | Jeffrey Epstein is the grantor of the Butterfly Trust. |
| Neptune LLC | Sole Member & Shareholder | Jeffrey Epstein | Jeffrey Epstein is the sole member and shareholder of Neptune LLC. |
| Neptune LLC | Manager | Richard Kahn | Richard Kahn is the manager of Neptune LLC. |
| 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. |
| Neptune LLC | Authorized Signer | Harry Beller | Harry Beller is an authorized signer for Neptune LLC. |
| Neptune LLC | Authorized Signer | Darren Indyke | Darren Indyke is an authorized signer for Neptune LLC. |
| SOW Company | Employee | JSC Interiors LLC | Karyna Shuliak's SOW Company is JSC Interiors LLC. |
Notable Quotes 3
Just wanted to remind you that KYC Case#IIIIIIII also requires your review and submission to AML as per attached email. This case has 2 other accounts, so we will have 5 high risked accounts submitted today.
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. The reason for this request is to evaluate whether we require CDD form for this account or not.
Neptune LLC — Please note that Richard Kahn has been added as manager as per Operating Agreement even though he was NOT added as an RP in the previously approved KYC Case!
Red Flags 3
- High-risk accounts associated with Jeffrey Epstein
- Discrepancies in KYC documentation (e.g., Richard Kahn not initially listed as RP for Neptune LLC)
- Unclear relationship between UBOs and grantor of Butterfly Trust
Financial Information
Assets:
- Butterfly Trust
- Neptune, LLC
Public Knowledge
- Context
- The involvement of Jeffrey Epstein and Deutsche Bank in handling high-risk accounts is likely to be of interest to the media.
- Media Worthy
- Yes
Legal Compliance
- KYC compliance for high-risk accounts
- AML compliance
- CDD form requirements for trusts
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowLegal matters/litigationBusiness dealingsCommunications/correspondenceCompliance issues
People 11
Organizations 9
Deutsche Bank Trust Company AmericasDeutsche Bank Wealth ManagementDeutsche Bank Securities Inc.Deutsche CIB Centre Private LimitedDeutsche Bank GroupButterfly TrustNeptune, LLCJSC Interiors LLCAML team
Locations 3
345 Park Avenue, New York, NY 10154Mumbai, IndiaNirlon Knowledge Park, Western Express Highway, Goregaon East, Mumbai - 400063, India
Financial Entities 1
Deutsche Bank
Text Analysis
- Tone
- Professional
- Purpose
- The purpose of the email chain is to review and approve KYC (Know Your Customer) documentation for high-risk accounts, including Butterfly Trust and Neptune, LLC, to ensure compliance with AML (Anti-Money Laundering) regulations.
- Significance
- The document is significant because it involves the review of high-risk accounts associated with Jeffrey Epstein and other individuals, highlighting the bank's efforts to comply with KYC and AML regulations.
File Info
- File Name
- EFTA01420904.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:42:42.566553
- DOJ Source
- View on DOJ