Illegal Activity
suspicious
Blackmail
possible
Date
2018-08-24
Document Type
email
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This email discusses the 2018 periodic review of high-risk accounts, including the Butterfly Trust and Neptune LLC, both linked to Jeffrey Epstein. It requests clarification on the nature of the Butterfly Trust and confirmation of material changes and RP's for both accounts to ensure compliance with KYC and CDD requirements.
Metadata
- Subject
- RE: 2018 Periodic Review of High Risked Accounts (GCIS#489505), Butterfly Trust (GCIS#486426) and Neptune, LLC (GCIS#487264) under the SOUTHERN FINANCIAL RELATIONSHIP [I]
- Sender
- Vijay-A Sawant
- Recipients
- Stewart Oldfield, Richard Iarossi
- Document ID
- GCIS#489505, GCIS#486426, GCIS#487264, KYC Case#01790739
- Date
- 2018-08-24
Illegal Activity
- Severity
- suspicious
- Description
- The document does not contain clear evidence of illegal activity. However, the mention of Jeffrey Epstein as the grantor of the Butterfly Trust and sole member/shareholder of Neptune LLC, combined with the need for KYC/CDD compliance, raises suspicion due to Epstein's history.
- Content Type
- first_hand
Blackmail Indicators
- Likelihood
- possible
- Description
- The document itself does not contain explicit blackmail indicators. However, the context of high-risk accounts and the need for strict compliance, combined with the association with Jeffrey Epstein, raises the possibility that any discrepancies or non-compliance could be used as leverage.
Relationships 8
| 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. |
| Neptune LLC | Sole Member & Shareholder | Jeffrey Epstein | Jeffrey Epstein is the Sole Member & Shareholder of Neptune LLC. |
| Neptune LLC | Manager | Richard Kahn | Richard Kahn is the Manager of Neptune LLC. |
| 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 | Karyna Shuliak | Karyna Shuliak works for JSC Interiors LLC. |
Notable Quotes 2
Butterfly trust — 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 3
- High-risk accounts associated with Jeffrey Epstein requiring periodic review.
- Discrepancies in the classification of the Butterfly Trust.
- Addition of Richard Kahn as manager of Neptune LLC without updating the KYC case.
Financial Information
Assets:
- Butterfly Trust
- Neptune LLC
Public Knowledge
- Context
- The association with Jeffrey Epstein and the scrutiny of his financial accounts would likely be of interest to the media.
- Media Worthy
- Yes
Legal Compliance
- Potential misclassification of Butterfly Trust as a Family Trust when UBOs have different surnames and nationalities.
- Need for CDD form depending on whether Butterfly Trust is deemed a Corporate Trust.
- Richard Kahn being added as manager of Neptune LLC without being added as an RP in the previously approved KYC case.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowBusiness dealingsCommunications/correspondence
People 11
Organizations 5
Deutsche CIB Centre Private LimitedDeutsche Bank GroupNeptune, LLCButterfly TrustJSC Interiors LLC
Locations 3
Mumbai, IndiaGoregaon East, Mumbai - 400063, IndiaNirlon Knowledge Park, Western Express Highway
Financial Entities 1
Deutsche Bank
Text Analysis
- Tone
- Professional
- Purpose
- To request confirmation and clarification regarding high-risk accounts under review, specifically Butterfly Trust and Neptune LLC, to ensure compliance with KYC and CDD requirements.
- Significance
- The document highlights the scrutiny of accounts linked to Jeffrey Epstein and the need for accurate KYC/CDD information, particularly regarding the nature of the Butterfly Trust and the roles of individuals associated with Neptune LLC.
File Info
- File Name
- EFTA01421973.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:39.168965
- DOJ Source
- View on DOJ