Classification: Confidential Wayne, Enhanced Due Diligence was conducted on Southern Financial LLC, a Private Investment Vehicle incorporated in the U.S. Virgin Islands, which is a Level II country, as the result of a New Client Adoption request to open a Global Markets relationship. The below is for your review and approval. Nature of Escalation — • The escalation is due to the client being a Private Investment Vehicle, which is considered High risk. Note: The documentation for this account is available for review on the shared drive via the following path: L:\Central_Functions_Compliance \Comp-nyseccom \ Varela \ AML\ Pending Investigations, EDD, EDRs\Southern Financial LLC\ Research Findings (LEXIS/GOOGLE SEARCHES) — • Southern Financial LLC is a private investment vehicle incorporated under the laws of the Virgin Islands of the United States. The sole member of Southern Financial LLC is Southern Trust Company, Inc. which is also incorporated in the U.S. Virgin Islands. The sole shareholder of Southern Trust Company, Inc. is Jeffrey Edward Epstein. Ownership/UBOs — • Jeffrey Edward Epstein is the sole UBO and a control person of Southern Financial LLC. He is an American financier and science and education philanthropist. He 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 U.S. Virgin Islands, which merged into Southern Financial LLC. The source of wealth is from his career at Bear Stearns and his financial management firms. PCR/RDC Alerts — • RDC alerted to negative information on a control person and UBO of Southern Financial LLC, Jeffrey Edward Epstein. Epstein is a registered sex offender. Since 2005, there have b