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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01298890: Holder and Offshore (DS10)

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This document is a bank account compliance checklist for Deutsche Bank referencing an account holder with a U.S. address but non-U.S. signatory status, located in the Virgin Islands. It includes AML (Anti-Money Laundering) compliance approvals, reputational risk assessments, and references to ICIJ offshore investigations. The account value is listed as $272,436 and includes brokerage products.

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PersonKeyword
Excerpt 1
signatory is non-U.S. but has a U.S. address) 0 AFC Reputational Risk Approval (gambling nexus) 0 AML Compliance & BRM Approval for US persons with an **offshore**
Excerpt 2
50% or more of client [x] Google/Internet searches: Client and UBO- at a minimum 0 Group Sustainability Approval (environmental/social risk) [x] ICIJ **Offshore**
Excerpt 3
Deutsche Bank / Account **Holder** Name J.

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