EFTA01656415

FinCEN I Financial Crimes Enforcement Network UnIttci Sacs ()optimal( tithe Treasury BSAR Transcript BSA: 31000155725098 and DCN: Filing Information Type of Report Continuing Activity Report Filing Date 10/11/2019 Received Date 10/11/2019 Entry Date 10/15/2019 Amended Prior BSA ID: 31000150416250 Submission Method Electronic discrete filing Subject Information Suaj•ctl • Role Subject Subject Type Purchaser/Sender Individual/Organization Individual Last(or Entity) Name EPSTEIN First Name JEFFREY Gender Type Male Date of Birth ././.1 SSN/ITIN Form(s) of Identification Identification Type Passport Identification Number Issuing Country Code US Address(es) Address Type Subject permanent/mailing address Street Address 6100 RED HOOK QUARTER B3 6100 RED HOOK QUARTER B3 - Enhanced City ST THOMAS ST THOMAS - Enhanced State VI VI - Enhanced ZIP Code 008021348 00802-1348 - Enhanced Country VI US - Enhanced Phone Number(s) Type Work Number Email(s) Occupation/Type of Business Executive/Southern Trust Co. Corroborative Statement to Filer No Page 1 The enclosed nformatico was corrected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Deportment of the Treasury regdations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chapter X. The reformation a sensitive ti nature and is to be treats accadingly. The information may be used only for a purpose consistent with acr.-mat tax. or regulatory nvestigation or proceeding. or in the conduct of intelligence or counterntelligence activities. indueng analysis. to protect against nternational terrorism. See 31 U S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Frnancial Craws Enforcement Network or he authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of pass.ble criminal activity. akin to ccofidential informant tips. Unauthorized release of information collected wider the BSA may result in aiminal or civil :wens:. 8605ZL5510001£:bSB EFTA01656415 FinCEN I Financial Crimes Enforcement Network United Sums Departmait elute Ttaouty BSAR Transcript BSA: 31000155725098 and DCN: Subject Information Relationship to Financial Institution(s) Institution TIN 941737782 Relationship of Subject Customer. Yes Affected Account(s) Account 1 of 2 Account Number 41224708 Closed Yes Financial Institution TIN 941737782 Account 2 of 2 Account Number 14332170 Closed Yes Financial Institution TIN 941737782 Subject 2 of 4 : KAHN Role Subject Subject Type Purchaser/Sender Individual/Organization Individual Last(or Entity) Name KAHN First Name RICHARD Gender Type Male Date of Birth SSN/ITIN Form(s) of Identification Identification Type Passport Identification Number Issuing Country Code US Address(es) Address 1 of 3 Address Type Subject permanent/mailing address Street Address City State ZIP Code Country I US - Enhanced Address 2 of 3 Address Type Subject permanent/mailing address Street Addres Page 2 The enclosed nformatico was ca ected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury regaations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chapter X. The nformation a sensitive ti nature and is to be treats accadingly. The information may be used only fa a purpose consistent with acrtnoal, tax. or regulatory nvestigation or proceeding. or in the conduct of intelligence or counterntelligence activities. incluttn analysis. to protect against nternational terrorism. See 31 U S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Frnancial Craws Enforcement Netwakor he authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passtle criminal activity. akin to ccofidential informant tips. Unauthorized release of information collected wider the BSA may result in criminal or civil :webs:. 86093L99WOOIC.VSO EFTA01656416 FinCEN Financial Crimes Enforcement Network United States Dcpanntent dike Treasury BSAR Transcript BSA: 31000155725098 and DCN: Subject Information City State ZIP Code Country US US - Enhanced Address 3 of 3 Address Type Subject permanent/mailing address Street Address City State ZIP Code Country US US - Enhanced Phone Number(s) Phone Number 1 of 2 Type Work Number Phone Number 2 of 2 Type Mobile Number Email(s) Occupation/Type of Business Executive/HBRK ASSOCIATES INC Corroborative Statement to Filer No Relationship to Financial Institution(s) Institution TIN 941737782 Relationship of Subject Customer. Yes Affected Account(s) Account 1 of 2 Account Number Closed Yes Financial Institution TIN 941737782 Page 3 The enclosed mformation was caected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regaations implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The mformation is sensitive m nature and is to be treats accadingty. The information may be used only fa a purpose con ustent with a crammat. tax. or regulatory myestigation or proceeding. or in the conduct of mtelligence or countermtelligence activities. incluttlg analysis, to protect against mtemational terrorism. See 31 U S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Financial Crnes Enforcement Netwakon his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passtle criminal activity. akin to ccofidential informant tips. Unauthorized release of information collected wider the BSA may result in criminal or civil :miens:. 8609ZL9510001C.VSO EFTA01656417 FinCEN I Financial Crimes Enforcement Network United Soto Doparmait t4 the pussy BSAR Transcript BSA: 31000155725098 and DCN: Subject Information Account 2 of 2 Account Number 14332170 Closed Yes Financial Institution TIN 941737782 Role Subject Subject Type Purchaser/Sender Individual/Organization Organization Last(or Entity) Name SOUTHERN COUNTRY INTERNATIONAL INC. EIN 660821138 Form(s) of Identification Identification Type Other Other Text CORPORATION FORMATION DOCUMENTS Issuing State Code VI Issuing State Virgin Islands, U.S. Issuing Country Code VI Address(es) Address Type Subject permanent/mailing address Street Address 6100 RED HOOK QTRS STE 8-3 6100 RED HOOK QTRS STE 8-3 - Enhanced City ST THOMAS ST THOMAS - Enhanced State VI VI - Enhanced ZIP Code 008021348 00802-1348 - Enhanced Country VI US - Enhanced NAICS Code 5239 NAICS Code Text Other Financial Investment Activities Phone Number(s) Type Work Number (340) 775-2525 Relationship to Financial Institution(s) Institution TIN 941737782 Relationship of Subject Customer. Yes Affected Account(s) Account Number 14332170 Closed Yes Financial Institution TIN 941737782 Role Subject Page 4 The enclosed mformaticn was ca ected and disseminated under provisions of the Bank Secrecy Act (Me SSA) and U.S. Department of the Treasury regttations implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The mformation a sensitive n nature and is to be treats accadingty. The information may be used only fa a purpose consistent with acrmoa tax. or regulatory nvestigation or proceeding. or in the conduct of intelligence or counterntelligence activities. incluctIg analysis. to protect against ntemational terrorism. See 31 U S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Fnancial Craws Enforcement Network or his authorized delegate. Suspicious activity reports filed under the GSA must be treated with particular care given that they contain unsubstantiated allegations of pass.ble criminal activity. akin to ccofidential informant tips. Unauthorized release of information collected wider the GSA may result in criminsi or civil :webs:. 86053L99LCHNIC VS8 EFTA01656418 FinCEN I Financial Crimes Enforcement Network Usual Sores Degrattmast of the Treasury BSAR Transcript BSA: 31000155725098 and DCN: Subject Information Subject Type Purchaser/Sender Individual/Organization Organization Last(or Entity) Name SOUTHERN TRUST COMPANY INC. EIN 660779861 Form(s) of Identification Identification Type Other Identification Number 1217721L Other Text Secretary of State Issuing State Code VI Issuing State Virgin Islands, U.S. Issuing Country Code VI Address(es) Address Type Subject permanent/mailing address Street Address 6100 RED HOOK QUARTER B3 6100 RED HOOK QUARTER B3 - Enhanced City ST THOMAS ST THOMAS - Enhanced State VI VI - Enhanced ZIP Code 008021348 00802-1348 - Enhanced County VI US - Enhanced NAICS Code 5221 NAICS Code Text Depository Credit Intermediation Phone Number(s) Type Work Number (340) 775-2525 Relationship to Financial Institution(s) Institution TIN 941737782 Relationship of Subject Customer. Yes Affected Account(s) Account Number 41224708 Closed Yes Financial Institution TIN 941737782 Suspicious Activity Information Amount Involved $45,360,202 Cumulative Amount $73,018,526 Date or Date Range of Activity 07/15/2019 - 09/03/2019 Money laundering Suspicious EFT/wire transfers Financial instrument or payment mechanism Funds transfer Page 5 The enclosed nformation was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chwter X. The nformation is sensitive n nature and is to be treated accoddingty. The information may be used only for a purpose consistent with a etyma& tax. or regulatory evestigation or proceeding. or in the conduct of ntelligence or counterntelligence activities. inclueng analysis. to protect against nternational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. dixlosed. or transmitted without pith approval of the Director of Estancia Crates Enforcement Network or his authorized delegate_ Suspicious activity reports fled under the BSA must be treated with particular care given that they contain unsubstantiated allegations of pa:cable criminal activity. akin to cooklenbal informant tips_ Unauthorized release of information collected ruder the BSA may result in criminal or civil sanctions. 86093L99LOOOIC VSO EFTA01656419 FinCEN I Financial Crimes Enforcement Network United Sums Department of Mc rtirbuty BSAR Transcript BSA: 31000155725098 and DCN: Activity Location No Branch Activity Involved Yes Type of Financial Institution Securities/Futures Subsidiary of financial/bank holding company Clearing broker-securities Primary Regulator SEC RSSD Number 1026641 Legal Name Charles Schwab & Co., Inc EIN 941737782 Address Address Type Address where transaction occurred Street Address 211 Main St 211 MAIN ST - Enhanced City San Francisco SAN FRANCISCO - Enhanced State CA CA - Enhanced ZIP Code 94105 94105-1905 - Enhanced Country US US - Enhanced Internal Control File Number CA154479 Filer Information Primary Regulator Federal Reserve Filer Name The Charles Schwab Corporation EIN 943025021 Address Address Type Reporting party address Street Address 211 Main St 211 MAIN ST - Enhanced City San Francisco SAN FRANCISCO - Enhanced State CA CA - Enhanced ZIP Code 94105 94105-1905 - Enhanced Country US US - Enhanced Type of Financial Institution Other. Savings and Loan Holding Company Page 6 The enclosed mformatico was caected and disseminated under provisions of the Bank Secrecy Act (Me SSA) and U.S. Department of the Treasury regdations implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The mformation a sensitive m nature and is to be treated accadingly. The information may be used only for a purpose consistent with germinal, tax. or regulatory investigation or proceeding. or in the conduct of mtelligence or countermtelligence activities. inclueng analysis. to protect against mtemational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Palencia Crates Enforcement Network or he authorized delegate. Suspicious activity reports ftled under the GSA must be treated with particular care given that they contain unsubstantiated allegations of passtle criminal activity. akin to confidential informant tips. Unauthorized release of information collected wider the BSA may result in criminal or civil sanctions. 8605ZLSSLOONC VSO EFTA01656420 • CEN I Financial Crimes Enforcement Network n UnItai Scams Department tithe Ticaouty Ci2 BSAR Transcript BSA: 31000155725098 and DCN: Filer Information RSSD Number 1026632 Internal control/file number CA154479 Contact for Assistance Full Name AMLI - AML Investigations Phone Number Phone Type Work Law Enforcement Information Law Enforcement Agencies Contacted Agency Name DEPARTMENT OF JUSTICE (DOJ) SOUTHERN DISTRICT OF NEW YORK Law Enforcement Contact(s) Full Name ALEX ROSSMILLER Phone Number Phone Type Work Contact Date 07/14/2019 Narrative This Continuing Activity SAR is being filed by The Charles Schwab Corporation on behalf of Charles Schwab & Co., Inc. ("Schwab"), a registered broker dealer, as a result of continued concerning activity initially reported on 07/13/2019 (DCN 31000150416250). The initial SAR was filed due to concerns with attempted wires for the purpose of real estate, in light of negative media surrounding Jeffrey Epstein. There appears to be continuing outgoing activity of concern in the amount of S45,360,202.00, given the continued negative media surrounding Jeffrey Epstein and his estate. Please refer to internal number CA154479 when requesting more information regarding this report. The four subjects of this continuation SAR are: 1. Southern Trust Company LLC who established a relationship with Schwab in April 2019 consisting of a corporate brokerage account, 4122-4708. The company is registered in the United States (U.S.) Virgin Islands, license number 1-21-772-1L, as a business and management consulting firm, and was established in December 2018. 2. Southern Country International, LTD who established a relationship with Schwab in April 2019 consisting of a corporate brokerage account, 1433-2170. Per account documentation the company is established in the US Virgin Islands, formally Page 7 The enclosed reformation was connected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regdations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chwter X. The eformation is sensitive it nature and is to be treated accordingly. The information may be used only for a purpose consistent with a crineal. tax. or regulatory evestigation or proceeding. or in the conduct of etelligence or counteretelligence activities. inclueng analysis, to protect against etemational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Feancial Cranes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passable criminal activity. akin to ccnklenbal informant tips_ Unauthorized release of information collected trader the BSA may result in criminal or civil sanctions. 8609ZL99100016:VS9 EFTA01656421 inCEN I Financial Crimes Enforcement Network Unita' Saws Deparoncric of the Tanury \ C.0 BSAR Transcript BSA: 31000155725098 and DCN: Narrative registered as the Financial Strategy Group Ltd and is in the financial services industry. 3. Jeffrey Epstein (66 years old) established a relationship with Schwab in April 2019 and acts as an internal control person and beneficial owner on three accounts; the role does not grant him authority to act upon the Schwab accounts. Jeffrey Epstein is deceased as of 08/10/2019, but is included as a subject of this SAR due to the negative media involving Federal charges. His disclosed employer is an Executive at Southern Trust Company Inc. 4. Richard Kahn (46 years old) established a relationship with Schwab in April 2019 consisting of three active corporate accounts. His disclosed employment is a Senior Executive at HBRK Associates Inc. Richard Kahn appears to be a close business partner in various ventures with Jeffrey Epstein, including Southern Trust Company. The outgoing activity of concern during this continuation investigative occurred in two of the Schwab accounts. The Schwab corporate brokerage account 41224708 registered to Southern Trust Company, Inc., and the Schwab corporate brokerage account 14332170 registered to Southern Country International, LTD. Richard Kahn is the authorized agent on both of the accounts, providing him the authority to act upon the accounts, and Jeffrey Epstein is listed as an internal control person and 100 percent beneficial owner; Jeffrey Epstein does not have any authority to act upon the accounts. Schwab made a business decision to terminate the relationship with Jeffrey Epstein, Richard Kahn, and the entities associated with the corporate accounts. As of the filing of this SAR, the three accounts have been closed and Schwab has ceased the relationship with Jeffrey Epstein, Richard Kahn, Southern Trust Company LLC, Southern Country International, LTD, and Southern Financial LLC. Schwab's continuation investigation encompassed the time period ranging from 07/11/2019 to 09/18/2019. The activity in question occurred between 07/15/2019 and 09/03/2019, referenced in Part II, line 30 of this SAR. The dollar amount $45360,202.00, referenced in Part II, line 29 of this SAR, represents the total amount of outgoing activity of concern which were identified during the continuation investigation review. The cumulative filing amount $73,018,525.94, referenced in Part II, line 31 Page 8 The enclosed eformation was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seg.: 31 CFR Chapter X. The eformation is sensitive it nature and is to be treated accordingly. The information may be used only for a purpose consistent with a crams{ tax. or regulatory evestigation or proceeding. Of in the conduct of etelligence a counteretelligence activitiesoncludeg analysts, to protect against eternabonal terrorism. See 31 U.S.C. 5311. The information carnal be further released. disseminated. dixlosed. or transmitted without per approval of the Director of Feancial Crates Enforcement Network or his authorized delegate- Suspicious activity reports fled under the BSA must be treated with particular care given that they contain unsubstantiated allegations of pa:cable criminal activity. akin to co:tridental informant tips- Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. 8609ZL991000IX:VSEI EFTA01656422 F nCEN I Financial Crimes Enforcement Network Unita' Sows peps IIIICIC a the Tanury BSAR Transcript BSA: 31000155725098 and DCN: Narrative of this SAR is the total amount of activity of concern reported in the initial SAR filed on 07/13/2019 and this SAR filing. Jeffrey Epstein was arrested and federally charged on 07/08/2019 with one count of sex trafficking of minors, and one count of conspiracy to engage in sex trafficking of minors, alleging the activity took place between2002 and 2005, possibly with an exchange of funds for acts. Jeffrey Epstein was held in Federal custody as prosecutors considered Jeffrey Epstein a very high flight risk given his enormous wealth, international ties, and private planes. On 08/10/2019, Jeffrey Epstein was found deceased while in jail by an apparent suicide. Per internet research two days prior to Jeffrey Epstein's death, he executed his last will and testimony where it appears his assets were moved into a trust that has been filed in the US Virgin Islands. The executors of Mr. Epstein's will are Richard Kahn and Darren Indyke. The initial SAR filed by Schwab on 07/13/2019 (DCN 31000150416250) reported concerns with international wires attempted to be remitted from the Schwab account registered to the Southern Financial LLC to an individual in Morocco for real estate purposes. In light of the negative media surrounding Jeffrey Epstein, which included a bail hearing, Schwab filed to report the attempted money movement for an individual considered a flight risk. The outgoing wires were attempted to be remitted to Marc Leon, a partner at Kensington Morocco, which appears to offer luxury properties in Morocco and France (www.kensingtonmorocco.com). The attempted international wires which were identified in the initial investigation review were ultimately canceled or reversed at the request of the account agent, Richard Kahn. During this continuation investigation, additional outgoing funds remitted from the accounts up until account closure raised concerns given the continued media coverage on Jeffrey Epstein. It should be noted the outgoing funds were primarily remitted between 07/15/2019 and 08/02/2019, while Jeffrey Epstein was alive in Federal custody and before his will was executed and filed in the US Virgin Islands. Between 07/15/2019 and 08/.2019, the two corporate accounts sent 16 individuals wires for an aggregated amount of $45,354,912.12. The wires were sent to individuals and companies that appear connected and/or associated with Jeffrey Epstein as follows: Page 9 The enclosed nformatico was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFA Chyle; X. The nformation is sensitive n nature and is to be heated accadingly. The information may be used only Ice a purpose conustent with acanna& tax, or regulatory nvestigation or proceeding. or in the conduct of ntelligence or counterntelligence activities. induct-5g analysis, to protect against ntemational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without pia approval of the Director of Financial Crates Enforcement Network or his authorized delegate_ Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passable criminal activity. akin to ccnklenhal informant tips- Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. 8609ZLS91000IX:VSEI EFTA01656423 FinCEN I Financial Crimes Enforcement Network United SOICS Dept (mai r u u.< Lmusy BSAR Transcript BSA: 31000155725098 and DCN: Narrative Eleven of the 16 wires were remitted to accounts held at TD Bank that appear to be registered to: HBRK Associates Inc. NES; HBRK Associates Inc. Neptune; HBRK Associates Inc. LSJ; HBRK Associates Inc. Plan D; HBRK Associates Inc. Hyperion; HBRK Associates Inc. Zorro; and HBRK Associates Inc. JEGE, for various amounts for an aggregated amount of S14,660,567.89. HBRK Associates Inc. is actively registered in the State of New York with Richard Kahn as the registered agent. A Bloomberg article indicated HBRK Associates Inc. allegedly helped arrange travel for Epstein's accusers between New York and Florida. The identifiers or acronyms that were listed after the beneficiary name of HBRK Associates Inc., were also listed in the wire memos for example -HBRK Associates Inc. NES" with the memo "NES LLC - BILL PAY " or "HBRK Associates Inc. ZORRO" with the memo stating -ZORRO - BILL PAY." Research of the identifiers listed appear to reference to a businesses or possible assets associated to Mr. Epstein as follows: LSJ appears to be an acronym to reference Little St. James (LSJ), the smaller private island owned by Mr. Epstein and according to lawsuits is where Epstein ran a "complex commercial sex trafficking and abuse ring." NES appears to be associated to the company that owned Epstein's New York Mansion located at Nine East 71st Street (NES), and ZORRO appears to be Epstein's ranch located in New Mexico. The identifiers JEGE, PLAN D, and HYPERION appear to be shell companies which held or still are the owners of Epstein's Gulfstream aircrafts. NEPTUNE appears to be a business associated to Epstein's address in which allegedly donated money to a democratic campaign in 2014. In addition, one wire was remitted to LSJE LLC to an account at FirstBank Puerto Rico listing Epstein's address as the beneficiary address listing "FUNDING OPERATING ACCOUNT" as the memo for S2,536,513.89.Per open source media, LSJE LLC appears to control Little St. James Island, pay employees of the island, linked to various imports as the consignee of various items shipped to and from the islands. Page 10 The enclosed eformaticn was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seg.: 31 CFR Chapter X. The eformation is sensitive al nature and is to be treated accccdingty. The information may be used only la a purpose con ustent with a crime* tax. or regulatory evestigation or proceeding. or in the conduct of etelligence or counteretelligence activities. inclueng analysis, to protect against eternational terrorism. See 31 US.C. 6311. The information cannot be further released. disseminated. disclosed. or transmitted without vim approval of the Director of Feancial Cranes Enforcement Netwarkor his authorized delegate Suspicious activity reports fled under the BSA must be treated with particular care given that they contain unsubstantiated allegations of par.c.ible criminal activity. akin to calla:lento' informant tips- Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. 8609ZL591000IX:VS9 EFTA01656424 Fit-IGEN I Financial Crimes Enforcement Network United bows Deparimoit ti the Ticbuty BSAR Transcript BSA: 31000155725098 and DCN: Narrative While the following four wires were remitted to beneficiaries appearing to be lawyers, given the negative media surrounding Jeffrey Epstein, research is unable to definitely identify if they are of concern: Two wires were remitted to DARREN K INDYKE PLCC IOLA TRUST ACCOUNT for a total amount of $12,657,830.34. One of the wires listed "escrow for legal fees." Per open source media, Darren Indyke is a lawyer based in New York, as well as the co- executor of Mr. Epstein's estate. Per an article posted by the Wall Street Journal, Darren Indyke established companies, handled matters involving charitable giving, and represented in real estate dealings for Mr. Epstein. MARTIN G. WEINBERG, PC received one wire for $3,500,000.00. Per research is a lawyer in Boston offering attorney services for white collar crime and appeared to be representing Jeffrey Epstein. STEPTOE JOHNSON LLP, appearing to be an international law firm offering criminal services received one wire for $12,000,00.00. As a result of account closure, Schwab issued two checks on 08/02/2019 and 09/03/2019 to Southern Trust Company Inc. (6100 RED HOOK QUARTER B3 ST THOMAS US Virgin Islands) for a total of $5,289.82, the remaining funds in the account. Please see the attached CSV for detailed information regarding the outgoing funds of concern as noted above. Schwab determined to file this SAR reporting continued concerns with outgoing funds identified between the initial SAR filing and the Schwab initiated closure of the accounts, given the continued negative media surrounding Jeffrey Epstein and his estate. Schwab maintains all supporting documentation. Written requests for supporting documentation may be sent to . Please refer to internal number CA154479 when requesting more information regarding this report. Page 11 The enclosed eformation was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 USG. 5311. et seq.: 31 CFR Chapter X. The eformation is sensitive a nature and is to be treated accordingly. The information may be used only la a purpose con ustent with a crime* tax. or regulatory evestigation 04 proceeding. Of in the conduct of etelligence Of counteretelligence activitiesoncludeg analysis. to protect against eternahonal terrorism. See 31 LIS.C. 5311. The information cams be further released. disseminated. disclo--ed. or transmitted without vim approval of the Director of Feancial Crates Enforcement Network or his authorized delegate_ Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passable criminal activity. akin to cceklenbal informant tips. Unauthorized release ol information collected under the BSA may result in criminal or civil sanctions. 8609ZL991000IX:Val EFTA01656425