EFTA01481907

Ticket# 105258633 Client Name ECI LOB JEEPERS, INC. 0241857215 PB Account# Account Title Account Type Initiated Date Initiator Initiating Team 07/13/2013 07:22 AM JUSTIN D NELSON PB FRONT OFFICE Verify & Confirm for JEEPERS, INC. Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators Reason for Adjustment Comments Summary of Risk Attributes Please summarize any material changes which have occurred with the client within the past 12 months: Creation Date Risk Updated History Entered by GCS Grid Search Type Company Information Corporate Records Other Database Searches (RDC/MIS/Factiva) Internal Database Search (CSSS/FPS) No changes on activity at this time. High High Full No Derogatory information - Jeffrey Epstein personally is flagged as High Risk due to felony conviction. Updated Risk EFTA01481907 Previous Risk Comment Security Service Details No records found. Further Review Required No No records found. Information confirmed; details included in the attachment. • Internal database search revealed prior GS&I research for Jeffrey Edward Epstein and the following derogatory information was reported: Several newspaper articles were found that detail the indictment of Jeffrey Epstein in Florida on felony charges of soliciting underage prostitutes. Jeffrey Epstein served 13 months in jail. Numerous articles detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating in child trafficking and molesting underage girls. Jeffrey Epstein is required to register as a sex offender. Jeffrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding solicitation for an undisclosed amount. State Court Searches Federal Court Searches Personal Particulars Publications Regulatory Sanctions OFAC/Control List Search Negative or Inconsistent Information GCS Red Dot Has this been identified as Red Dot KYC? Negative Information Found Banker Attestation Details You are about to approve a high risk client. Have you included sufficient information to satisfy High Risk Enhanced Due Diligence regulatory requirements (Section 312 of the USA Patriot Act)? As the client sponsor, I understand that I am primarily responsible for protecting the firm's reputation from inappropriate business relationships, as well as from fraud and money laundering. By approving this KYC, I am sponsoring this client as to their character and reputation and from a legal/regulatory standpoint. Yes Yes EFTA01481908 No Yes No records found. No records found. No records found. Nothing derogatory found. No records found. A search of OFAC did not reveal any matches. No No No No No No Yes No Yes Yes EFTA01481909 Please state your rationale for conducting business with this client Please respond to any issue(s) identified in the GS&I grid that either needs further review, or red dot which is not already covered in a Business Case within this KYC Comments Primary Information Client Type Client Status Confidential Names? Legal Business Name Jeffrey Epstein was asked to exit the firm in August of 2013. The accounts are in the process of moving to another bank and should be closed out by year-end. Jeffrey Epstein was asked to exit the firm in August of 2013. The accounts are in the process of moving to another bank and should be closed out by year-end. Non Individual Client No Front Office Restricted? Active Indicator JEEPERS, INC. Country of Primary Domicile UNITED STATES Primary Country of Assets VIRGIN ISLANDS, U.S. Country of Organization Industry Code (NAIC) Client Legal Entity Type Date of Incorporation/Situs (Date of Trust) Documentary Evidence What is the nature/purpose of this entity? UNITED STATES Personal Investment Companies Corporation 08/18/2003 Corporation - Certified Articles of Incorporation The purpose of this entity is personal investments on behalf of Jeffrey Epstein. Is the entity a Personal Holding Company (PHC) or Personal Investment Company (PIC) located in an offshore jurisdiction? PHC/PIC Questions Are shares registered or in bearer form EFTA01481910 List the total number of shares that have been issued High Risk Jurisdiction Address(es) Type Legal Notes Address 6100 RED HOOK QUARTER B3 Phone(s)/Fax(s) Type Work Notes Phone Tools Verify "Do Not Call" List Email(s) Type Other Notes Email Entered by EILEEN MORIARTY 02/19/2013 Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team GIO Trust Advisor Decision Maker Date of Update Preferred Yes Entered by SYSTEM Date of Update 12/08/2011 Preferred Yes City, State, Postal Code ST THOMAS, EFTA01481911 00802 Country VIRGIN ISLANDS, U.S. Tools Map it Entered by Date of Update BATCH Preferred 12/22/2011 Yes Registered 1000.0 Yes What is the authorized capital(This information is usually found in the Board Resolution and/or minutes) 1000.0 Yes Insider Code (Reg. 0) Primary Domicile State WebSite Organization State Secondary Industry Code (NAIC) Client Category Virgin Islands NAIC NOT PROVIDED [ ] Profit Normal Yes Virgin Islands Client Client Type JUSTIN D NELSON 002753 - GREENWICH CHBG (DE) 4 Paul S Barrett JEFFREY E EPSTEIN New or Existing Client Entity Type Portfolio Manger Investor DM ECI Non Individual Existing Entity EFTA01481912 EFTA01481913 Identification Withholding Federal Status Domestic Certified Withholding SSN/TIN Certification Date SSN/TIN/EIN Introduction & Wealth Introduction Type Net Worth of client($) Additional Party Information ECI Party Type Party Name Last Completed Search Date Individual Jeffrey E Epstein 04/18/2013 KYC Status Report Type Relation Type Completed Full Sole Owner Powers Percent Owned 100.0 12/08/2011 Existing JPMorgan Client - Inside LOB 50,000,000.00 Primary Information for Jeffrey E Epstein Client Type Client Status Front Office Restricted? Confidential Names? First Name Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Individual Client Normal No Country of Primary Domicile UNITED STATES Prefix/Title EFTA01481914 Jeffrey E Epstein UNITED STATES High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Legal Notes Address 6100 RED HOOK QTRS STE B3, Phone(s)/Fax(s) Type Home Notes er Tools Verify "Do Not Call" List Email(s) Type Other Notes Email Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team Identification Withholding Federal Status Withholding SSN/TIN Certification Date Entered by BATCH Date of Update 03/20/2013 Preferred Yes Entered by BATCH Date of Update Preferred 02/22/2013 Yes EFTA01481915 City, State, Postal Code ST THOMAS„ 00802 Country VIRGIN ISLANDS, U.S. Tools Map it Entered by Date of Update BATCH Preferred 08/03/2012 Yes INDIVIDUALS ] Personal Investment Companies AIM Generation Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets Jeffrey E Epstein Male 01/20/1953 UNITED STATES Yes Single Client Client Type PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 Entity Type Decision Maker Individual EFTA01481916 SSN/TIN/EIN Form of government issued identification obtained for the files Primary Identification Number Date Issued Introduction & Wealth Introduction Type Net Worth of client($) Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth from following list of options Other Issued By Expiration Date Introduction Non Individual Entity Type For Profit? Locations Served? a. If International or both, please describe: Corporation - For Profit Yes Both To conduct its business in the Virgin Islands and elsewhere in the United States and foreign countries and to have offices within or outside the Virgin Islands and to hold, purchase, mortgage and convey real and personal property within or outside the Virgin Island. Public or Private Are beneficial owners/principal shareholders associated with this business? Who owns this entity? Please Provide ownership details Private Yes Individual Jeffrey Epstein is the sole owner of the corporation - Jeffrey Epstein DOB: 01 20 1953 SSN: Citizen: United States Govt ID: US Virgin Islands - CI - Issued 1/15/2010 - Expires - 1/20/2015 Ownership is not equal to 100%? Are there any authorized signers or any other individuals with authority over the entity? What independent background check, in addition to the Global Corporate Security ("GCS") background check, has been carried out? Check all that apply and provide the date in which the background check was conducted. (at least 1 EFTA01481917 must be selected) JPMC Network Date JPMC Network Comments No No JPMC Network 12/08/2011 This is another part of an existing client relationship with Jeffrey Epstein. An ECI was created for this entity in the Retail Bank but no account number was ever assigned. We are moving this ECI from Retail to Private Bank to open an asset/brokerage account. Politically Exposed Person Are any of the beneficial owners/authorized signers or other individuals with authority over this entity a current or former Senior United States or Non-USA Political Official / also known as a Politically Exposed Person (PEP) or related to one? Source of Wealth/Financial Information Client Category(for SOW) Source of Wealth- identify the clients source of wealth from the following list of options No For Profit Other EFTA01481918 Provide detailed and specific information. The source of wealth will derive from the personal assets of Jeff Epstein. Jeff Epstein is self-em toyed investor/entrepreneur. Jeffrey Epstein (SSN: DOB: 01/20/1953 US Citizen) is an existing client of PB. He is an active brokerage client across asset classes currently covered by the Firm's GIO desk. Jeffrey Epstein has been an investment advisor for numerous high net worth clients and also a personal investor. Jeffrey is very accessible and well known to the team. We have advised him on investments as well as estate planning opportunities. Jeffrey has continues to be well connected across business channels. Epstein is well known to several JPM PB employees and senior management including Jes Staley. Also, Mr. Epstein was convicted of a felony charge in 2008. Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB client. Mr. Epstein completed his sentence and probation in 2010. The relationship has been reviewed with senior management and compliance/legal on a few occasions over the post year as news stories of Jeffrey's past are picked up. No new claims or stories have surfaced recently. Which country(ies) is(are) the Client's primary Source of Wealth or Income derived? Is this an Operating Company? Total Net Worth $ What was the total net worth based on? Is this client a Professional Service Provider acting as a financial intermediary (Gatekeeper/Financial Liaison), with assets held on behalf of one or more unidentified underlying clients unknown to the bank? Is this entity a Private Equity Fund (Venture Capital Fund or Leveraged Buyout)? 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.) 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.) Is this entity any of the following business types? Is the Entity a Personal Holding Company (PHC) or Personal Investment Company (PIC) located in an offshore jurisdiction? Is the PHC/PIC managed by JPMC? (Trustees of the entity are JPMC employees, e.g., PHC managed in Nassau/Geneva/Delaware) PHC/PIC Location Did the client confirm with you that the beneficial ownership is as stated within this KYC? EFTA01481919 Did the client confirm that he/she would inform you if beneficial ownership changes? Was the "Confirmation of Beneficial Ownership" document received from the beneficial owner? Please attach the J.P. Morgan Confirmation of Beneficial Ownership document to the KYC. List the number of shares that have been issued Business Case Please specify why you are comfortable with this client given the identified risk factor(s). Your answer is your "business case" and should detail all mitigating factors. 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. Client known to whom (JPMorgan employees), how well, and how long: Overall PB/PWM relationship size and type of accounts: 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? When was the last time you met the client? What was the reason for the meeting? Describe any significant changes in the client's information or material events that may have occurred over the last year (Examples: address changes, change in authorized persons on accounts, change in account type, change in business, change in net worth, etc,). Cash Activity: Summarize client cash activity during the period reviewed and explain the purpose / use of the funds: Wire Activity: Summarize client wire activity during the period reviewed and explain the purpose / use of the funds, including any international/cross border wires: Jeffrey Epstein was asked to exit the firm in August of 2013. The accounts are in the process of moving to another bank and should be closed out by year-end. Jeffrey has been a client for over 10 years. Senior management, including Mary Erdoes, knows Jeffrey. >$100 million No I met with the client in June of 2013 Jeffrey Epstein was asked to exit the firm in August of 2013. The accounts are in the process of moving to another bank and should be closed out by year-end. All accounts are in the process of transitioning to Deutsche Bank, so all cash is moving out. All accounts are in the process of transitioning to Deutsche Bank, so wire activity has diminished 1000.00 UNITED STATES No 50000000.00 EFTA01481920 Financial Statements No No No No aa. None of the above Yes No Have you received copies of the shares or listing of shares? Yes Are the shares registered or in bearer form? Registered VIRGIN ISLANDS, U.S. Yes Yes Yes EFTA01481921 Before answering the following question please review the Annual Account History Activity Summary Report that has been attached in the Summary tab. Did the actual transaction activity appear reasonable, normal, and expected for the type of business or industry in which the client engages? Was the nature, value, and volume of actual transaction activity consistent with expected transaction activity? Was any unusual or potentially suspicious transaction activity detected? Additional Comments Expected Activity Client Directed Asset / Brokerage Account(s) Transaction Types Cash Deposits Cash Withdrawals Check Deposits Checks Paid Incoming Wires (Domestic) Outgoing Wires (Domestic) Incoming Wires (International) Outgoing Wires (International) ACH Deposits ACH Payments Internal Transfer (Debits/Credits) Asset Purchases/Sales Low (1-10) <$10,000 What is the initial/ongoing source of funding for the client's Client Directed Asset / Brokerage Account(s) ? The initial source of funding will be from an external wire tranfer of funds from First Bank Virgin Islands Bank in the amount of $800. Any ongoing source of funding will also be from First Bank Virgin Islands Bank from returns on various investments. What is the purpose/intended use of account(s)? Please provide a detailed description of how the Client Directed Asset / Brokerage Account(s) will be used by the client. The purpose of the account is to purchase securities for future wealth accummulation. Review the activity for the period overall and explain how the client's transaction profile agrees with or doesn't agree with expectations for the client based on the client relationship (purpose of accounts, occupation, business activity, etc.): This account continues to have low activity. Was expected activity for the client modified in the transaction activity section of the KYC ticket? No Additional Client Information Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc. Jeffrey Epstein (SSN: DOB: 01/20/1953 US Citizen) is an existing EFTA01481922 client of PB. He is an active brokerage client across asset classes currently covered by the Firm's GIO desk. Jeffrey Epstein has been an investment advisor for numerous high net worth clients and also a personal investor. Jeffrey is very accessible and well known to the team. We have advised him on investments as well as estate planning opportunities. Jeffrey has continues to be well connected across business channels. Epstein is well known to several JPM PB employees and senior management including Jes Staley. Also, Mr. Epstein was convicted of a felony charge in 2008. Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB client. Mr. Epstein completed his sentence and probation in 2010. The relationship has been reviewed with senior management and compliance/legal on a few occasions over the post year as news stories of Jeffrey's past are picked up. No new claims or stories have surfaced recently. Comment History Stage Name Market Manager Approval CEO Approval Low (1-10) <$10,000 Expected Activity Levels Anticipated Dollar Amount Totals per Month Yes Yes No N/A Creation Date Entered By 12/06/2013 02:35 PM 12/15/2013 07:02 PM TOWNSEND C SMITH JOHN R DUFFY Comment Preview We are exiting this relationship approved to facilitate exit of client from jpm Approval History Stage Name Banker Attestation Market Manager Approval Regional Director Approval CEO Approval Signoff Date 11/15/2013 06:03 PM 12/06/2013 02:35 EFTA01481923 PM 12/06/2013 03:40 PM 12/15/2013 07:02 PM DF#@&T15#7@1 Owner SID U008568 U117517 U095563 U093971 Owner Name JUSTIN D NELSON TOWNSEND C SMITH WILLIAM M SHERIDAN JOHN R DUFFY EFTA01481924