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efta-efta01415698DOJ Data Set 10Correspondence

EFTA Document EFTA01415698

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DOJ Data Set 10
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efta-efta01415698
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
General Notes Ensure photo ID is clear and legible Ensure documentation is in date (photo ID is valid, proof of address within 6 months) Ensure name on documentation matches investor name exactly Ensure signature list is in the name of the Client If not appropriate backup should be received e.g. Trust deed if trustee signing on bahalf of a pension scheme Power of attorney signed by investor authorising another entity to sign on their behalf Administraton agreement if administrator signing on behalf of a fund If AML documentatuin is received in one large file - note the relevant pages on the checklist Schedule 3 Countries Argentina, Australia, Austria, Bahamas, Bahrain, Barbados, Belgium, Bermuda, Brazil, British Virgin Islands, Canada, Cyprus, Denmark, Finland, France, Germany, Gibraltar, Greece, Guernsey, Hong Kong, Iceland, India, Ireland, Isle of Man, Israel, Italy, Japan, Jersey, Liechtenstein, Luxembourg, Malta, The Netherlands, New Zealand, Norway, People's Republic of China, Portugal, Singapore, Spain, Sweden, Switzerland, United Arab Emirates, United Kingdom and United States of America. Certified Copies All certified copies should be certified by a chartered and certified public accountant, notaries public, solicitor, embassy and consular staff or a representative of your bank, registered broker-dealer or other regulated financial institution. Each document should be marked with the words 'original seen' or 'true' copy of original documents'. The document should be signed by the individual certifying the document and noting their capacity and licence number (if applicable). unicode ms,Regular"For internal use only EFTA01415698 Private Company PRIVATE COMPANIES (EXCLUDING LIMITED LIABILITY COMPANIES) Incorporation Account Holder Name & GCIS# JEGE Inc & 487244 Scanned Copy of a certificate of due formation and organisation (e.g. certificate of incorporation/registration) Yes (Old COGS available but SOS extracted from Delaware) if this is not provided you can verify online independently from the local govt company registry, if applicable Scanned Copy of the Memorandum and Articles of Association or equivalent Yes (AOI) Data Points - Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID of the entity Yes ( AOI & W9) Jeffrey Epstein President & Authorized Signatory Scanned Copy of authorised Signatory List or Corporate Resolution Yes (2013) Harry Beller Authorized Signatory Scanned Copy of the Register of Members/shareholders (beneficial owners) listing the name address and DOB (if DOB is applicable) of each person who directly, or indirectly, is the beneficial owner of more per cent of any voting or non-voting class of equity interests of the company than >10% (for High risk) ; >25% (for low & moderate risk) Share Certificate confirming sole ownership by Jeffrey epstein available Copy of the Register of Director NA Director: collect full AML documentation - complete relevant checklist based on entity type of all directors ID docs available for Jeffrey Epstein Does the entity issue Bearer Shares? If so request letter from regulated custodian (e.g. lawyer) confirming that they hold the shares and will advise us of any change in ownership No Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth Jeffrey Epstein's SOW available AML documention for all beneficaries >10% (High) & 25% (Low & Moderate)- use relevant checklist based on entity type of beneficary (Use HIGH risk requirements) Must identify beneficiaries through to ultimate beneficial owner ID docs available for Jeffrey Epstein Last PCR/RDC searches done Yes If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. This is a company formed to hold funds for the taxes and payments of one of Jeffrey Epstein's airplanes. This LLC was formed to eventually take over payments for JEGE Inc. JEGE Inc will be closed within a year Previous KYC Case# 1790820 Completed by Alka Babu Date 7/31/2018 &"arial unicode ms,Regular"For internal use only EFTA01415699 Individual INDIVIDUAL &/or Joint Acct Holder Account Holder Name & GCIS# Full Name, DOB, Place of Birth, Gender, Country of Citizenship & Residence, SSN/Gov ID copy of picture identification bearing signature (specify if valid) Occupation, Employer's Name & Address, Estimated Income, Net Worth & Soucre of Wealth Fircosoft, RDC & BIS Searches last done Previously Approved KYC Cases Additional proof of address is dated within the last 6 months Last PCR/RDC searches done If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. KYC Case# Completed by Date &"arial unicode ms,Regular"For internal use only EFTA01415700 Limited Liability Company LIMITED LIABILITY COMPANIES Account Holder Name & GCIS# Copy Certificate of Formation (or equivalent) if this is not provided you can verify online independently from the local govt company registry, if applicable Copy operating agreement or equivalent Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID Name & address of all Managing Members (if individual also obtain date of birth) Enter name of Members Name & address of all Members who own >10% (High risk) ; >25% (Low & Moderate risk) (if individual also obtain date of birth) Managing Members- Collect full AML documentation - complete relevant checklist based on entity type of each member Copy authorised signature list or Corporate Resolution Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth AML documention for all members >10% (High risk); >25% (Low or Moderate) - cmplete relevant checklist(s) based on entity type of member Last PCR/RDC done If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Completed by Date 64"arial unicode ms,Regular"For internal use only EFTA01415701 Listed Company THE INVESTOR MUST BE A REGULATED ENTITY IN A SCHEDULE 3 COUNTRY Listed Companies Account Holder Name & GCIS# Proof of listing from relevant stock exchange Name of listed entity must match the investor name exactly Copy authorised Signatory List or Corporate Resolution Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID If the entity is classified as HIGH risk e.g. not in specified country this checklist should not be used Refer to relevent checklist as per entity type e.g. Private company Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Last PCR/RDC done Completed by Date &"arial unicode ms,Regular"For internal use only EFTA01415702 Public Body Public/Government body Account Holder Name & GCIS# Screenprint of website confirming entity status as a public body Details of all public / government body officials (name, residential address, date of birth & occupation) Copy of Authorised Signatory List or Corporate Resolution Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID OR, if the above is not available: Certified copy of the relevant Constitution/Formation Document; Copy of Authorised Signatory List. Details of all public / government body officials (name, residential address, date of birth & occupation) Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth PLUS if the entity is classified as HIGH risk e.g. PEP or not in specified country collect full AML for public or governmental body officials : Public body official AML documentation - complete relevant checklist (Use HIGH risk requirements) Last PCR/RDC done If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Completed by Date &"arial unicode ms,Regular"For internal use only EFTA01415703 Pension Scheme Pension Scheme Account Holder Name & GCIS# Copy of the relevant Revenue/Tax Authority approval certificate e.g. IRS approval letter or web-site print out detailing the relevant Revenue/Tax Authority approval Ensure this matched the name of the investor exactly Copy of Authorised Signatory List or Corporate Resolution Copy of the rules of the scheme confirming (1) that contributions are made by the employer or by way of deduction from employee's wages and (2) that the rules of the scheme do not permit the member's interest to be re-assigned Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID OR, if not registered with a relevant tax authority or pension board: Certified copy of the relevant Constitution/Formation Document; Name of the Trustees/Directors/Governors or equivalent Identification of the scheme's administrator who is responsible for conducting the relevant AML checks on clients (additional documentation may be required in respect of the scheme administrator once they have been identified) Certified copy or original Authorised Signatory List or Corporate Resolution Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth PLUS if the entity is classified as HIGH risk e.g. PEP or not in specified country Also obtain AML for trustees: Trustee AML documentation - complete relevant checklist based on entity type of each trustee (use higher risk requirements) Last PCR/RDC done If account is opened in the name of trustee company on behalf of pension scheme see Pension scheme trustee checklist If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Completed by Date 64"arial unicode ms,Regular"For internal use only EFTA01415704 Pension Scheme Trustee Pension Scheme Trustee Account Holder Name & GCIS# Online verification of Trustee company (from relevant company registration site) Copy of the deed showing the relationship between the trustee company and the scheme Ensure the trustee name on the deed matches the client name Copy of the relevant Revenue/Tax Authority approval certificate e.g. IRS approval letter or web-site print out detailing the relevant Revenue/Tax Authority approval Ensure this matched the name of the pension scheme Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID Copy of Authorised Signatory List or Corporate Resolution Copy of the rules of the scheme confirming (1) that contributions are made by the employer or by way of deduction from employee's wages and (2) that the rules of the scheme do not permit the member's interest to be re-assigned Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth OR, if not registered with a relevant tax authority or pension board: Online verification of Trustee company (from relevant company registration site) Copy of the deed showing the relationship between the trustee company and the scheme Ensure the trustee name on the deed matches the client name Certified copy of the relevant Constitution/Formation Document; Name of the Trustees/Directors/Governors or equivalent Identification of the scheme's administrator who is responsible for conducting the relevant AML checks on clients (additional documentation may be required in respect of the scheme administrator once they have been identified) Certified copy or original Authorised Signatory List or Corporate Resolution PLUS if the entity is classified as HIGH risk e.g. PEP or not in specified country Also obtain AML for trustees: Trustee AML documentation - complete relevant checklist based on entity type of each trustee (use higher risk requirements) Last PCR/RDC done If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Completed by Date &"arial unicode ms,Regular"For internal use only EFTA01415705 Trusts Private Trusts Account Holder Name & GCIS# Copy of the Trust Deed or equivalent constitutional document Copy of authorised Signatory List or Corporate Resolution Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID List of ALL beneficial owners/controllers or class of beneficiaries If no named beneficary has confirm who has control of the trust Name address & Date of birth of trustees Name address & Date of birth of settlor(s)/grantor(s) Trustee 1: Collect full AML documentation - complete relevant checklist based on entity type of trustee Trustee 2 (or authorised signer) : collect full AML documentation - complete relevant checklist based on entity type of trustee Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth Last PCR/RDC done If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Completed by Date &"arial unicode ms,Regular"For internal use only EFTA01415706 Limited Partnerships Partnership Account Holder Name & GCIS# Copy of the Partnership Agreement or equivalent Details of all partners (name, residential address, date of birth, occupation & ownership) Copy of Authorised Signatory list or Corporate Resolution or Signature Card Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID for the entity General partner collect full AML documentation - complete relevant checklist based on entity type of each GP Enter name of GP Limited partner collect full AML documentation - complete relevant checklist based on entity type of each LP Enter name of LP 1 ID Docs for GP's owning >25% interest ID Docs for LP's owning >25% interest Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth PLUS if the entity is classified as HIGH risk e.g. PEP or not in specified country Collect AML documentation for GP/LP listed above in line with higher risk requirements collect full AML documentation for all partners who own more than 10% (High risk) of the partnership capital, profit, or voting rights use relevant checklist based on entity type of the partner Last PCR/RDC done If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Completed by Date &"arial unicode ms,Regular"For internal use only EFTA01415707 Charities Registered Charity Account Holder Name & GCIS# Copy of the relevant Revenue/Tax Authority approval or proof of registration status from the relevant Charity Commission or equivalent e.g. IRS approval letter or website print-out Copy of Authorised Signatory list or Corporate Resolution or Signature Card Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID for the entity Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth PLUS if the entity is classified as HIGH risk e.g. PEP or not in specified country Certified copy of the relevant Constitutional/Formation Document Certified copy or original Authorised Signatory List Details of each Trustee/Director/Governor (or equivalent) Enter names Details of beneficiaries/class of beneficiaries (where ascertainable) Enter name Certified copy of the Audited Financial Statements. Trustee/Director Govenor : AML documentation - complete relevant checklist based on each entity type (use higher risk requirements) Enter name of trustee/Director/Govenor Last PCR/RDC done If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Completed by Date &"arial unicode ms,Regular"For internal use only EFTA01415708 School College Universities School/College/University Account Holder Name & GCIS# Confirmation of whether the entity is Publicly Owned or Privately Owned If the entity is publicly-owned, use public body checklist Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID for the entity If privately owned identify beneficial owners and obtain AML as per relevant checklist Details of the main officials (name, residential address, date of birth, and occupation). Authorised Signatory List or Corporate Resolution or Signature Card For Each Public body official collect full AML documentation - complete relevant checklist (Use HIGH risk requirements) Name, address & date of birth of beneficial owners >10% (High Risk); >25% (Low or Moderate Risk) Enter name of beneficial owners Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth PLUS if the entity is classified as HIGH risk e.g. PEP or not in specified country Collect AML documentation for officials listed above in line with higher risk requirements Collect full AML documentation for beneficial owners >10% - complete relevant checklists) Last PCR/RDC done If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Completed by Date &"arial unicode ms,Regular"For internal use only EFTA01415709 Fund Funds Account Holder Name & GCIS# Copy of the Offering Memorandum/PPM or equivalent Name and address of the fund's promoter and administrator Proof that the entity conducting the relevant AML checks on the underlying investors of the fund is regulated in a Specified Country if entity conducting AML is not regulated in a Specified Country look to high risk requirements Details of all investors who own more than 25 per cent of the shares/units in the Fund Legal Address, Date & Country of Incorporation, Residence, Tax Id/Gov ID for the entity Industry, Nature of Business, Source of Wealth, Source of Funds, Estimated Income& New Worth PLUS if the entity is classified as HIGH risk e.g. Administrator is not regulated, investor is a PEP or not in specified country Collect full AML documentation for all shareholders with >10% (high-risk) holding (complete relevant checklist(s) Last PCR/RDC done If any exceptions have been approved by AML in the past, please make a note here. Same to be done regarding any alerts & negative media on RP's. Previously Approved KYC Case# Completed by Date 64"arial unicode ms,Regular"For internal use only EFTA01415710

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