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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01478399: Holder, Beneficial Owner and Tax Evasion (DS10)

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An internal compliance document discussing potential tax evasion procedures. The document outlines guidelines for account managers and relationship managers to identify and escalate potential tax evasion risks involving account holders and ultimate beneficial owners.

👤 Named in This Document
🔑 Evidence Keywords

📋 Key Excerpts6

PersonKeyword
Excerpt 1
above (or any other factors or information of which the RM / IA is aware), the RM / IA has reason to believe the Account Holder/UBO could be engaged in **tax**
Excerpt 2
**evasion**, the RM / IA should not provide the confirmation below and should instead raise the matter with their supervisor.
Excerpt 3
Client Risk Program - Affirmation and Escalation Guideline Account **Holder** Name (s) : Account Number Ultimate Beneficial Owner(s) (UBO), if different from

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