EFTA Document EFTA01481573

Ticket# 104748662 Client Name ECI LOB JEGE INC 0220476622 PB Verify & Confirm for JEGE INC Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators Reason for Adjustment Comments Summary of Risk Attributes 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) Account# Account Title Account Type Initiated Date Initiator Initiating Team 03/26/2013 09:47 AM CHRISTINE HEWITT PB FRONT OFFICE Standard High Full No Not associated with high risk jurisdictions. No derogatory information found. Updated Risk Previous Risk Comment Security Service Details Information not confirmed for Jege Inc (Tax EFTA01481573 ID ); details included in the attachment. Information confirmed; details included in the attachment. No records found. Internal database search revealed prior GS&I research for .7 Epstein and Co. and nothing derogatory to report. *** 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 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. Please state your rationale for conducting business with this client Yes No Yes No records found. No records found. No additional research necessary. Nothing derogatory found. EFTA01481574 No records found. A search of OFAC did not reveal any matches. No No No No No No Yes Further Review Required Yes No No Yes This is an entity 100% owned by Jeffrey Epstein. EFTA01481575 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 Issues are well documented in JE's personal KYC. Non Individual Client No Front Office Restricted? Active Indicator JEGE INC Country of Primary Domicile UNITED STATES Primary Country of Assets 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? High Risk Jurisdiction Address(es) Type Legal Notes Address 6100 RED HOOK QUARTER B3 Phone(s)/Fax(s) Type Notes Phone address not available Email(s) Type Notes Email address not available Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team GIO Trust Advisor EFTA01481576 Decision Maker Identification Withholding Federal Status Domestic Certified Withholding SSN/TIN Certification Date SSN/TIN/EIN Introduction & Wealth Introduction Type Net Worth of client($) 03/26/2013 510405649 Email Entered by Date of Update Preferred Phone Number Tools Entered by Date of Update Preferred City, State, Postal Code ST THOMAS, 00802 Country VIRGIN ISLANDS, U.S. Tools Map it Entered by Date of Update BATCH Preferred 11/21/2012 Yes UNITED STATES Personal Investment Companies [525997] Corporation 09/07/2000 Corporation - Certified Articles of Incorporation This entity is being phased out, it currently owns a personal plane. Yes Is the entity a Personal EFTA01481577 Holding Company (PHC) or Personal Investment Company (PIC) located in an offshore jurisdiction? No Insider Code (Reg. 0) Primary Domicile State WebSite Organization State Secondary Industry Code (NAIC) Client Category Delaware NAIC NOT PROVIDED [ ] Profit Normal Yes New York 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 9710670708 Non Individual Existing Entity Existing JPMorgan Client - Inside LOB 1,000,000.00 EFTA01481578 Additional Party Information ECI Party Type Party Name Last Completed Search Date 9710670708 Individual Jeffrey E Epstein 05/29/2012 KYC Status Report Type Relation Type Completed Full Sole Owner Powers Percent Owned 100.0 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 Jeffrey Epstein UNITED STATES Self Entrepreneur 0 Generation Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender EFTA01481579 Date of Birth Primary Country of Assets 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 Phone Number Tools Verify "Do Not Call" List Email(s) Type Other Notes Email ap@hbrkassociates. com Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team Identification Withholding Federal Status Form of government issued identification obtained for the files Date Issued Domestic Certified Drivers License Primary Identification Number 0000025874 01/15/2010 Introduction & Wealth Introduction Type Net Worth of client($) Issued By Expiration Date VIRGIN ISLANDS, U.S. 01/20/2015 EFTA01481580 Withholding SSN/TIN Certification Date SSN/TIN/EIN 09/18/2006 BATCH Date of Update 03/20/2013 Preferred Yes Entered by BATCH Date of Update Preferred 02/22/2013 Yes 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 Yes Single New York Jeffrey E Epstein Male 01/20/1953 UNITED STATES Individuals [999940] Personal Investment Companies [525997] Client Client Type JUSTIN D NELSON 002753 - GREENWICH CHBG (DE) 4 Entity Type Decision Maker Individual Existing JPMorgan Client - Inside LOB EFTA01481581 500,000,000.00 EFTA01481582 Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth from following list of options Other Introduction Non Individual Entity Type For Profit? Locations Served? Public or Private Are beneficial owners/principal shareholders associated with this business? Who owns this entity? Please Provide ownership details 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 must be selected) JPMC Network Date JPMC Network Comments Corporation - For Profit Yes Domestic Private No Individual Jeff Epstein is 100% owner No No JPMC Network 03/26/2013 The entity is 100% owned by Jeffrey Epstein and a complete DDR is on file for Mr. Epstein. Jeffrey Epstein is an existing client of PB. In years past, Mr. Epstein was an active brokerage client, particularly in foreign exchange, and as of this year he is a custody-only client. Formerly, Jeffrey Epstein was a money manager to high net worth individuals, most notably Leslie Wexner. Wexner was a JPM client and then retained Epstein in the late 90s. Mr. Wexner terminated his relationship with Epstein in 02/2008. Epstein is well known to several JPM PB employees and to Jes Staley. Mr. Epstein was convicted of a felony charge in 2008 and is currently serving an 18-month prison sentence. Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB client. Staley and PB then decided that his PB relationship will be for banking and custody only. We no longer provide brokerage execution capabilities for Mr. Epstein's accounts. Bear Stearns will hold the brokerage relationship with EFTA01481583 Mr. Epstein 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 What is the client's current executive management position? (Include any former positions, if significant to source of wealth) No For Profit Executive Management Epstein managed money for numerous high net worth families and has been an active investor himself. Epstein began his financial career in 1976 as an options trader at Bear Stearns. He specialized in mathematical models such as the Black-Scholes option-pricing model and later worked in the special products division, advising high net worth clients on tax strategies. In 1980, Epstein became a partner at Bear Stearns. In 1982, Epstein founded his own financial management firm, 3. Epstein & Co., managing the assets of clients with more than a billion in net worth. In 1987, Leslie Wexner, founder and chairman of the Columbus, Ohio—based Limited chain of women's-clothing stores became a well-known client. In 1996, Epstein changed the name of his firm to The Financial Trust Company and based it in the US Virgin Islands. List the number of years in current position. (Include any former positions, if significant to source of wealth) Approximate yearly income/salary/bonus/distribution and other compensation history (accumulated earned income) 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? 30 10000000 UNITED STATES No 1000000.00 Financial Statements EFTA01481584 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? Expected Activity Deposit 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 What is the initial/ongoing source of funding for the client's Deposit Account(s) ? Funding amount: $25,0000ther = Wire The ongoing soursce of funding will come from Jeff's personal accounts as needed, the money in that acccount comes from his investment income. 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 purpose of this company is to pay for the maintance of a plane. Credit Types of Credit Anticipated Dollar Amount Totals per Month Line of Credit 1,000.00 EFTA01481585 What is the purpose/intended use of account(s)? Please provide a detailed description of how the Credit will be used by the client. This entity currently has a coprorate credit issued to them. Monthly payments depend on monthly purchases Additional Client Information Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.) Country of Primary Assets: USA Jeffrey Epstein is an existing client of PB. He is an active brokerage client covered on the GIO desk. Jeff is well know to the integrated team and senior management. Jeffrey Epstein has been a money manager for high net worth individuals,entrepreneur and personal investor. the team has regular discussion with Mr. Epstein and he remains very accessible. Mr. Epstein is well known to several JPM PB employees. 6-18-10: Mr. Epstein completed serving out his house arrest. We have met regularly with compliance and legal do discuss the realtionship and any potential reputational risk concerns. We continue to monitor the situation closely and monitoring the occassional news stories regarding Mr. Epstein and civil lawsuits and monitor closely money movement. Mr. Epstein is managing his own personal wealth. January 27, 2011 update: A few news stories during 2010 connects Jeffrey Epstein to human trafficking. The coverage team along with Catherine Keating and William Langford all met to discuss the situation and agreed to enhance monitoring and document a discussion with the client. Jes Staley discussed the topic with Jeffrey Epstein who replied there was no truth to the allegations, no evidence and was not expecting any problems. We will continue to monitor the accounts and cash usage closely going forward. We continue to monitor the relationship closely and no additional stories or allegations have surfaced recently and Jeffrey maintain a professional rel;ationship with the PB and integrated team. Comment History Stage Name Low (1-10) Low (1-10) $500,001 TO $1,000,000 $500,001 TO $1,000,000 Expected Activity Levels Anticipated Dollar Amount Totals per Month No No No No aa. None of the above No Creation Date EFTA01481586 Entered By Comment Preview EFTA01481587 There are no comments entered at this time. Approval History Stage Name Banker Attestation Market Manager Approval Signoff Date 05/22/2013 02:15 PM 05/22/2013 02:38 PM DF#@&T15#7@1 Owner SID U008568 U117517 Owner Name JUSTIN D NELSON TOWNSEND C SMITH EFTA01481588