Illegal Activity
suspicious
Blackmail
possible
Date
2018-08-31
Document Type
email
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This email discusses a periodic review of high-risk accounts, specifically the Butterfly Trust and Neptune LLC, both linked to Jeffrey Epstein. The review raises questions about the classification of the Butterfly Trust and the addition of Richard Kahn as a manager of Neptune LLC, requiring further investigation for AML compliance.
Metadata
- Subject
- RE: 2018 Periodic Review of High Risked Accounts III ( ), 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
- KYC Case#01977698
- Date
- 2018-08-31
Illegal Activity
- Severity
- suspicious
- Description
- The document does not contain clear evidence of illegal activity. However, the discrepancies in the trust's classification and the addition of a manager without proper RP approval raise suspicions and warrant further investigation. The fact that Jeffrey Epstein is involved in these entities adds to the concern.
- Content Type
- first_hand
Blackmail Indicators
- Likelihood
- possible
- Description
- The document itself does not contain explicit blackmail indicators. However, the fact that Jeffrey Epstein is the grantor of the Butterfly Trust and sole member of Neptune LLC, combined with the KYC review flagging discrepancies in the trust's classification and the addition of a manager without proper RP approval, could potentially be exploited for leverage or coercion in other contexts.
Relationships 12
| 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 | Irina | Irina is a UBO of the Butterfly Trust. |
| Butterfly Trust | UBO | Darren Indyke | Darren Indyke is a UBO of the Butterfly Trust. |
| Butterfly Trust | UBO | Karyna Shuliak | Karyna Shuliak is a UBO of the Butterfly Trust. |
| Butterfly Trust | UBO | Richard Kahn | Richard Kahn is a UBO 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 of Neptune LLC. |
| Neptune LLC | Authorized Signer | Darren Indyke | Darren Indyke is an Authorized Signer of Neptune LLC. |
| Karyna Shuliak | SOW Company | JSC Interiors LLC | JSC Interiors LLC is the SOW Company for Karyna Shuliak. |
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.
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#01790739.
Red Flags 3
- The UBOs of the Butterfly Trust seem not related to the grantor, Jeffrey Epstein.
- The Volcker Questionnaire identifies the Butterfly Trust as a 'Family Trust' but this seems inaccurate.
- Richard Kahn was added as manager of Neptune LLC without being added as an RP in the previously approved KYC case.
Financial Information
Assets:
- Butterfly Trust
- Neptune LLC
Public Knowledge
- Context
- The involvement of Jeffrey Epstein in these financial entities, combined with the KYC review flagging discrepancies, would likely be of interest to media and journalists.
- Media Worthy
- Yes
Legal Compliance
- Need to determine if Butterfly Trust is a Personal Trust or Corporate Trust to determine if CDD form is required.
- Richard Kahn was added as manager of Neptune LLC without being added as an RP in the previously approved KYC case.
- Volcker Questionnaire reflects Butterfly Trust as a 'Family Trust' but this seems inaccurate due to different surnames and nationalities of UBOs.
- Need to confirm material changes to accounts and RPs.
- Fincen CDD form required for Neptune LLC.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowLegal matters/litigationBusiness dealingsCommunications/correspondence
People 12
Organizations 5
Butterfly TrustNeptune LLCDeutsche CIB Centre Private LimitedDeutsche Bank GroupJSC Interiors LLC
Locations 2
Mumbai, IndiaGoregaon East, Mumbai - 400063 , India
Financial Entities 1
Deutsche Bank
Text Analysis
- Tone
- Professional
- Purpose
- To request confirmation and clarification regarding the Butterfly Trust and Neptune LLC accounts as part of a periodic review of high-risk accounts.
- Significance
- The document highlights potential issues with the classification of the Butterfly Trust and the addition of Richard Kahn as a manager of Neptune LLC, requiring further investigation for AML compliance.
File Info
- File Name
- EFTA01436172.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:13.902089
- DOJ Source
- View on DOJ