EFTA01582793

Confidential Due Diligence Report Ghislaine Noelle Maxwell • Internal database search revealed the following: Reference the account(s) titled "Ghislaine Noelle Maxwell", "Forums LLC" 116 East 65th St LLC" & "Air Ghislaine, Inc" for previous research. The following information was previously reported to Mary Reith on 03/17/2003 Several newspaper articles detailing the investigation conducted by Britain's Serious Fraud Office against Robert Maxwell. He allegedly used pension funds to service debts, cover operating losses, gamble in the foreign exchange markets, and support the stock of his publicly held companies. The agency is also looking into a complaint from Swiss Bank Corp., which says it did not receive collateral for a $100 million loan to a small private Maxwell company. Newspaper article dated 12/01/2000, which stated that "Ghislaine Maxwell's source of wealth is being classified as something of a mystery." Newspaper article dated 08/09/1996 detailing the arrest of Ghislaine Maxwell on DWI charges. Numerous newspaper articles detailing the criminal fraud charges brought against Kevin and Ian Maxwell (sons of Robert Maxwell.). Newspaper article dated 6/23/2005 detailing Robert Maxwell misappropriated funds from the companies under his control. According to the newspaper article, "He pledged assets as security for additional loans", but instead of delivering the assets to the lender, he would simply sell the assets for cash. "For example, Berlitz language school was supposedly sold to a Japanese publishing company, but the shares had previously been pledged as security for loans from Swiss Volksbank and Lehman Brothers. • Publications revealed records found. On September 2009, Ghislaine Maxwell was subpoenaed in a suit against her friend Jeffrey Epstein. • Regulatory sanctions search revealed no additional information found. • A search of OFAC did not reveal any matches. Confidential - This report is not to be disseminated or photocopied to any third party without the express consent of Global Security & Investigations. [ FILENAME ] [ PAGE ] Confidential Treatment Requested by JPMorgan Chase JPM-SDNY-00062362 EFTA01582793