EFTA Document EFTA01480629

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? Yes Was the nature, value, and volume of actual transaction activity consistent with expected transaction activity? Yes Was any unusual or potentially suspicious transaction activity detected? No Additional Comments NIA Expected Activity Deposit Account(s) Transaction Types Expected Activity Levels Anticipated Dollar Amount Totals per Month Cash Deposits Cash Withdrawals Check Deposits Low (1-10) <510.000 Checks Paid Low (1-10) 4$10.00o Incoming Wires (Domestic) Low (1:10) 550,001 TO $MOCOO Outgoing Wires (Domestic) Low (1-10) $50.001 TOMO.= Incoming Winos (Inlomational) Outgoing Wires (International) ACH Deposits Low (1.10) <SIC 000 ACH Payments Low (1-10) <510.000 Internal Transfer (Debits/Credits) Low (1.10) <510.000 Asset Purchases/ales What is the Initial/ongoing source of fund ng for the client's Deposit Accounts) ? Indian, funding was a 200k wire. Ongoing funding will come frorn Mr. Epsiesn's personal accounts which are funded from his personal investment returns. What Is the purpose/Intended use of account(s)? Please provide a detailed description of how the Deposit Account(s) will be used by the client The purposerintended purpose of this account is receipt and distribution of consulting fees and operational activity to support a small office Review the activity for the period overall and explain how the clients 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.): The activity has lowered since the account opened. Was expected activity for the client modified In the transaction activity section of the KYC ticket? Yes If modified, explain. The activity has lowered since the account opened. It has a low activity. 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 is a longstanding client. He has dissolved his family office (New York Strategy Group) and has split it in two. HBRK Associates Inc. and Darren K Ind e PILO HBRK • rovides consuilin. services lo Mr. E Comment History CEO Approval Creation Date 12,06;2013 02 34 PM 12/1520130101 PM Entered B TCY/VNSEND C SMITH JOHN R DUFFY Comment Preview We arc exam. this relationsh • approved to facilitate closing of relationshii Approval History rIMUTIM • noff Date Owner SID Owner Name Banker Attestation 1112512013 06.50 PM 0008568 JUSTIN D NELSON ',lancet Manager A oval 12106201302:34 PM U117517 TOWNSEND C SMITH Regional Director A• oval 12/C8/201303:41 PM U095563 WILUAM M SHERIDAN CEO Approval 12/15/201307:01 PM U093971 JOHN R DUFFY Confidential Treatment Requested by JPMorgan Chase CONFIDENTIAL JPM-SDNY-00002834 SDNY_GM_00272032 EFTA01480629