EFTA Document EFTA01481812

Ticket# 105258609 Client Name ECI LOB Account# DARREN INDYKE Account Title 0221165201 PB Verify & Confirm for DARREN INDYKE Final Risk Rating High Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators Reason for Adjustment Comments Summary of Risk Attributes Please summarize any material changes which have occurred with the client within the past 12 months: Standard Full No Attorney of a convicted felon Accounts are to be monitored while relationship in in process of exit. Darren is the attorney of convicted felon, Jeffrey Epstein. 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 Indyke PLLC. HBRK provides consulting services to Mr. Epstein. Account Type Initiated Date Initiator Initiating Team 07/13/2013 07:22 AM JUSTIN D NELSON PB FRONT OFFICE Creation Date Risk Updated History Entered by Updated Risk GCS Grid Search Type Company Information Corporate Records EFTA01481812 Other Database Searches (RDC/MIS/Factiva) Internal Database Search (CSSS/FPS) 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 Comments Primary Information Client Type Client Status Front Office Restricted? Confidential Names? Yes No No Previous Risk Comment Security Service Details No records found. Further Review Required No No records found. No records found. No records found. No records found. No records found. Information confirmed; details included in the attachment. Nothing derogatory found. No records found A search of OFAC did not reveal any matches. No No EFTA01481813 No No No No No No No No Senior management (John Duffy) has communicated to the client a request to move the relationship and accounts from JP Morgan to another institurion. This is now in execution mode and client is moving his business. For the time being - the accounts sit with the Region Head for Tri State, Individual Client Generation Normal No Country of Primary Domicile UNITED STATES Prefix/Title Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Yes Married New Jersey EFTA01481814 First Name DARREN Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation INDYKE UNITED STATES Darren K. Indyke PLLC Lawyer 6 High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Legal Notes Address 2 KEAN COURT City, State, Postal Code LIVINGSTON , New Jersey, 07039 Phone(s)/Fax(s) Type Other Notes Phone Number 8624856315 Tools Verify "Do Not Call" List Email(s) Type Notes Email address not available Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team EFTA01481815 GIO Trust Advisor Decision Maker DM ECI Identification Withholding Federal Status Form of government issued identification obtained for the files Date Issued Domestic Certified Passport Primary Identification Number 112637684 03/10/2002 Introduction and Wealth Introduction Type Net Worth of client($) Additional Party Information No additional parties available at this time Introduction Form of government issued identification obtained for the files ? Passport Issued By Expiration Date UNITED STATES 03/10/2012 Withholding SSN/TIN Certification Date SSN/TIN/EIN 10/04/2013 000-00-0000 Email Entered by Date of Update Preferred Entered by SYSTEM Date of Update 02/12/2013 Preferred Yes Country UNITED STATES Tools Map it Entered by Date of Update BATCH Preferred EFTA01481816 10/07/2009 Yes No Individuals [999940] NAIC NOT PROVIDED [ ] Full Name Gender Date of Birth Primary Country of Assets DARREN INDYKE Male 02/19/1965 UNITED STATES Client Client Type WILLIAM M SHERIDAN 143360 - USPB UHNW NYC TRI STATE EXEC CHBG (DE) 4 Paul S Barrett JEFFREY E EPSTEIN 9710670708 Entity Type Portfolio Manager Investor Entity New or Existing Client Individual Existing Existing JPMorgan Client - Inside LOB 1,000,000.00 EFTA01481817 Has an employee of JP Morgan Wealth Management met the client in person? 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 Yes JPMC Network 02 Feb 2010 Darren Indyke is the longstanding internal counsel to Jeffrey Epstein (JPM client). Politically Exposed Person Is the client a current or former Senior United States or NonUSA Official / also known as a Politically Exposed Person (PEP), related to a PEP, or closely associated with a PEP? Source of Wealth/Financial Information Source of Wealth- identify the clients source of wealth from the following list of options Which country(ies) is(are) the Clients primary Source of Wealth or Income derived? What is the client's current position? (Include any former positions, if significant to source of wealth) Employment UNITED STATES Darren Indyke (SSN: 02/19/1965 DOB: 098-54-8596 US Citizen) is Jeffrey Epstein's attorney. 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. Indyke PLLC. HBRK provides consulting and accounting services to Mr. Epstein. Jeffrey Epstein is an existing client of PB. He is an active brokerage client across asset classes currently covered by the Firm's GIO desk. Jeffrey Epstein has been an investment advisor for numerous high net worth clients and also a personal investor. Jeffrey is very accessible and well known to the team. We have advised him on investments as well as estate planning opportunities. Jeffrey has continues to be well connected across business channels. Epstein is well known to several JPM PB employees and senior management including Jes Staley. Also, Mr. Epstein was convicted of a felony charge in 2008. Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB client. Mr. Epstein completed his sentence and probation in 2010. The relationship has been reviewed with senior management and compliance/legal on a few occasions over the post year as news stories of Jeffrey's past are picked up. No new claims or stories have surfaced recently. List the number of years in current position. (Include any EFTA01481818 former positions, if significant to source of wealth) Approximate yearly income/salary/bonus/distribution and other compensation history (accumulated earned income) Client Net Worth $ Documentation/Information obtained to confirm stated net worth of Client: Business Case Please specify why you are comfortable with this client given the identified risk factor(s). Your answer is your "business case" and should detail all mitigating factors. Provide client history/detail, including when the relationship was established, how it came to be in PB/PWM, client's association with other JPM LOBS, etc. Client known to whom (JPMorgan employees), how well, and how long: Overall PB/PWM relationship size and type of accounts: Is this a shared client, what other LOB has a relationship with the client? Provide relationship manager name (if known), client of other LOB since (date), and relationship size? When was the last time you met the client? What was the reason for the meeting? Describe any significant changes in the client's information or material events that may have occurred over the last year (Examples: address changes, change in authorized persons on accounts, change in account type, change in business, change in net worth, etc,). Cash Activity: Summarize client cash activity during the period reviewed and explain the purpose / use of the funds: Wire Activity: Summarize client wire activity during the period reviewed and explain the purpose / use of the funds, including any international/cross border wires: 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? The client is in the process of moving the entire relationship at the request of senior management (John Duffy). Relationship history dates back to referral form former 3PM senior executive (Jes Staley). Senior JPM exec Jes Staley. Active GIO client. No Previous bankers, GIO investors and Jes Staley. Last conversation with with John Duffy when request was made to exist the relationship. See above 16 1.7MM 1000000.00 Financial Statements EFTA01481819 No Client is in process of moving entire relationship. Client is in the proces of moving the entire relationship from the firm. Yes EFTA01481820 Was the nature, value, and volume of actual transaction activity consistent with expected transaction activity? Was any unusual or potentially suspicious transaction activity detected? Additional Comments Yes No As mentioned above - this relationship is now in the process of exiting JP Morgan. 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 Low (1-10) $50,001 TO $100,000 What is the initial/ongoing source of funding for the client's Deposit Account(s) ? The initial funding amount was a $60,0000ther = Wire. Ongoing will come from his PLLC account with the PB. 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 account is to be used for an IRA account and to pay the adminsitrative flows and fees. Review the activity for the period overall and explain how the client's 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 account has been reviewed. Was expected activity for the client modified in the transaction activity section of the KYC ticket? Yes If modified, explain. Yes, we added checks deposits and paid. Low activity for the account. Client Directed Asset / Brokerage Account(s) Transaction Types Cash Deposits Cash Withdrawals Check Deposits Checks Paid EFTA01481821 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 Client Directed Asset / Brokerage Account(s) ? The initial funding has already taken place. Ongoing will come from his PLLC account with the PB. What is the purpose/intended use of account(s)? Please provide a detailed description of how the Client Directed Asset / Brokerage Account(s) will be used by the client. IRA Account Buy and hold investments for his IRA account. Review the activity for the period overall and explain how the client's 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.): Expected activity/account has been reviewed and any ajustments have been made. Was expected activity for the client modified in the transaction activity section of the KYC ticket? No Additional Client Information Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.) 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 Low (1-10) Low (1-10) Low (1-10) Low (1-10) <$10,000 <$10,000 $50,001 TO $100,000 $50,001 TO $100,000 Expected Activity Levels Anticipated Dollar Amount Totals per Month EFTA01481822 Darren Indyke is the attorney for our client, Jeffrey Epstein. Mr. Indyke is opening an IRA with JPMorgan. Darren has been licensed to practice law in NY since 1992. Practice Areas International Law; Corporate Law; Tax Law; Securities Law; Litigation University Colgate University, B.A. Law School Cornell University, J.D. Comment History Stage Name Market Manager Approval MM/Banker Comments Market Manager Approval Creation Date Entered By 11/11/2013 12:57 PM 11/19/2013 09:01 AM 11/19/2013 10:37 AM JOHN R DUFFY WILLIAM M SHERIDAN JOHN R DUFFY Comment Preview Is Jeffrey Darren's only client? Per response from Justin Nelson (11/12) to the best of our knowledge Darren only works for JE. Approved to facilitate exit contemporaneously with JE Approval History Stage Name Banker Attestation Market Manager Approval Market Manager Approval CEO Approval Signoff Date 10/10/2013 09:34 AM 11/11/2013 12:57 PM 11/19/2013 10:37 AM 11/24/2013 07:27 PM DF#@&T15#7@1 Owner SID U095563 U093971 U093971 U093971 EFTA01481823 Owner Name WILLIAM M SHERIDAN JOHN R DUFFY JOHN R DUFFY JOHN R DUFFY EFTA01481824