EFTA01480815

Is this a Hedge Fund? (Pooled investment vehicles (often partnerships) that primarily invest financial capital of third party investors in enterprises that are too risky for the standard capital markets or bank loans.) No is this a Cash Intensive business? (Cash-intensive businesses/entities exist in various industry sectors and include, but are not limited to convenience stores, grocery stores, restaurants, bars, retail stores, liquor stores, cigarette distributors. privately owned ATMs. vending machine operators and parking garage operators.) No is this entity any of the following business types? aa. None of the above Is the Entity a Personal Holding Company (PHC) or Personal Investment Company (PIC) located in an offshore Jurisdiction? No Business Case Please specify why you are comfortable with this client given the identified risk lac tor(s). Your answer is your 'business case" and should detail all mitigating factors. Southern Trust Company is a new USVI entity owned by Jeffrey Epstein. The issues surrounding Jeffrey are well known and documented with senior management. Provide client history/detail, including when the relationship was established, how It came to be in PB/PWM, client's association with other JPM LOBS. etc. Jeffrey Epstein has been a client for many years. but the relationship only resides in the Private Bank. Client known to whom (JPMorgan employees), how well, and how long: Known to me, John Dully. Mary Erdoes. and others. Overall PEUPVVM relationship size and type of accounts: Total relationship is $125MM, but this entity is $15MM. However. this entily owns Southern Financial. with assets of about SWUM. is this a shared client, what other LOB has a relationship with the client? Provide relationship manager name (if known), client of other LOB since (date). and relationship size? No. Additional Comments N/A Expected Activity Deposit Account(s) Transaction Types Expected Activity Levels Anticipated Dollar Amount Totals per Month Cash Deposits Cash Withdrawals Check Deposits Low (I -10) c$10.000 Chocks Paid Low (I-10) <S10.000 Incoming Wres (Domestic) Outgoing Wiros (Domestic) Incoming Wires (International) Low (I-10) /,$ 10.000 Outgoing Wires (International) Low (I.10) <S10.000 ACH Deposits ACH Payments Internal Transfer (Debits/Credits) Asset Purchases/Sales What Is the initial/ongoing source of fund ng for the client's Deposit Accounqs)? The initial and ongoing source of finding will cone Jeffrey Epstein's clients who money his company manages. The nival source of funding came in the lorm of a wire from Leon Black in the amount of SISMA1. What is the purposeAntended use of account(s)? Please provide a detailed description of how the Deposit Account(s) will be used by the client. The purpose of this account is to pay the expenses of the INC. Client Directed Asset / Brokerage Account(s) Transaction Types Expected Activity Levels Anticipated Dollar Amount Totals per Month Cash Deposits Cash Withdrawals Check Deposits Checks Paid Incoming Wires (Domestic) Outgoing Wires (Domestic) Incoming Wires (International) Outgoing Wires (lAteM3Ii0(1.31) ACH Deposits ACH Payments Internal Transfer (Debits/Credits) Low (140) 510.009 TO $50.0O3 Asset Purchases/Sales Low (1-10) $ 10.090 TO $50,000 What is the initial/ongoing source of fund ng for the client's Client Directed Asset / Brokerage Account(s) ? The must and ongoing source of funding wall come from his clients. What is the purposehntended use of account(s)? Please provide a detailed descripbon of how the Client Directed Asset! Brokerage Account(s) will be used by the client. The purpose of this account is to invest cash assets. Confidential Treatment Requested by JPMorgan Chase CONFIDENTIAL JPM-SDNY-00003039 SDNY_GM_00272237 EFTA01480815