EFTA Document EFTA01481875

Ticket# 105258611 Client Name ECI LOB Account# THE HAZE TRUST Account Title Verify & Confirm for THE HAZE TRUST Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators Comments Summary of Risk Attributes Convicted Felon - 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. Please summarize any material changes which have occurred with the client within the past 12 months: 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) No other changes made. High High Full No Account Type Initiated Date EFTA01481875 Initiator Initiating Team 07/13/2013 07:22 AM JUSTIN D NELSON PB FRONT OFFICE Updated Risk Previous Risk Comment Security Service Details No records found. Further Review Required No No records found. No records found. Internal database search revealed prior GS&I research for Jeffrey Edward Epstein and the 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 You are about to approve a high risk client. Have you included sufficient information to satisfy High Risk Enhanced Due Diligence regulatory requirements (Section 312 of the USA Patriot Act)? As the client sponsor, I understand that I am primarily responsible for protecting the firm's reputation from EFTA01481876 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. Yes Yes No Yes No records found. No records found. No records found. Nothing derogatory found. No records found. A search of OFAC did not reveal any matches. No No Yes No No No No No No Yes EFTA01481877 Please state your rationale for conducting business with this client 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 Client has been ased to exit the firm and is in process of doing so now. Client has been asked to exit the firm and is in process of doing so now. Non Individual Client No Front Office Restricted? Active Indicator THE HAZE TRUST Country of Primary Domicile UNITED STATES Primary Country of Assets Country of Organization Industry Code (NAIC) UNITED STATES UNITED STATES Personal & Testamentary Trusts [525921] 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 Other Notes Phone Number EFTA01481878 3407752525 Tools Verify "Do Not Call" List Email(s) Type Other Notes Email [email protected] om Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team GIO Trust Advisor Decision Maker Identification Withholding Federal Status Domestic Certified Withholding SSN/TIN Certification Date SSN/TIN/EIN Introduction & Wealth Introduction Type 10/14/2013 137185414 Entered by FRANCIS G MCCLURE JR Date of Update Preferred 09/25/2012 Yes Entered by SYSTEM Date of Update 05/09/2011 Preferred Yes City, State, Postal Code ST THOMAS, 00802 Country VIRGIN ISLANDS, EFTA01481879 U.S. Tools Map it Entered by Date of Update BATCH Preferred 04/23/2010 Yes Trust 02/09/1999 Trust - Trust Agreement/other governing document establishing the Trust This is a Trust set up as part of Jeffrey Epstein's Estate Planning. Yes Estate Trust Revocable Trust Insider Code (Reg. 0) Primary Domicile State WebSite Organization State Secondary Industry Code (NAIC) New York NAIC NOT PROVIDED [ ] Normal Yes New York Client Client Type WILLIAM M SHERIDAN 143360 - USPB UHNW NYC TRI STATE EXEC CHBG (DE) 4 Paul S Barrett JEFFREY E EPSTEIN Entity Type Portfolio Manger Investor DM ECI 9710670708 Entity New or Existing Client Non Individual Existing Existing JPMorgan Client - Inside LOB EFTA01481880 Net Worth of client($) 10,000,000 00 Additional Party Information ECI Party Type Party Name Last Completed Search Date 0221165201 Individual DARREN INDYKE 01/15/2010 KYC Status Report Type Relation Type Completed Beneficiary Powers Percent Owned 100.0 Primary Information for DARREN INDYKE Client Type Client Status Front Office Restricted? Confidential Names? First Name Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Individual Client Normal No Country of Primary Domicile UNITED STATES Prefix/Title DARREN INDYKE UNITED STATES Darren K. Indyke PLLC Lawyer 6 High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type EFTA01481881 Legal Notes Address 2 KEAN COURT, City, State, Postal Code LIVINGSTON , New Jersey, 07039 Phone(s)/Fax(s) Type Other Notes Phone Number Tools 8624856315 Verify "Do Not Call" List Email(s) Type Notes Email address not available Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team Decision Maker Identification Withholding Federal Status Form of government issued identification obtained for the files Date Issued Domestic not certified SSN/TIN/EIN Passport Primary Identification Number 112637684 03/10/2002 Introduction & Wealth Issued By Expiration Date UNITED STATES 03/10/2012 000000000 Email Entered by Date of Update Preferred Entered by SYSTEM EFTA01481882 Date of Update Preferred 02/12/2013 Yes Country UNITED STATES Tools Map it Entered by Date of Update BATCH Preferred 10/07/2009 Yes Individuals [999940] Generation Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets Yes Married New Jersey DARREN INDYKE Male 02/19/1965 UNITED STATES Client Client Type WILLIAM M SHERIDAN 143360 - USPB UHNW NYC TRI STATE EXEC CHBG (DE) 4 JEFFREY E EPSTEIN Entity Type Entity Individual EFTA01481883 Introduction Type Net Worth of client($) Existing JPMorgan Client - Inside LOB 1,000,000.00 Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth from following list of options ECI Party Type Party Name Last Completed Search Date 9710670708 Individual Jeffrey E Epstein 04/18/2013 KYC Status Report Type Relation Type Completed Full 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 EFTA01481884 Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender 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 2127509895 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 Issued By EFTA01481885 Expiration Date VIRGIN ISLANDS, U.S. 01/20/2015 Withholding SSN/TIN Certification Date SSN/TIN/EIN 09/18/2006 090443348 Entered by 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 WILLIAM M SHERIDAN 143360 - USPB UHNW NYC TRI STATE EXEC CHBG (DE) 4 EFTA01481886 Entity Type Decision Maker Individual EFTA01481887 Introduction & Wealth Introduction Type Net Worth of client($) Existing JPMorgan Client - Inside LOB 500,000,000.00 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 Select Trust Type Is this an existing JPM trust or external trust? Is JPM Sole Trustee? Comments 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 Trust N/A Existing No Darren K. Indyke is a trustee (SSN: 098-54-8596 DOB: 02/19/1965 US Citizen) Jeffrey E. Epstein is the Grantor of this Trust (SNN: DOB: 01-20-1953 US Citizen) Yes JPMC Network 22 Apr 2010 Jeffrey Epstein is an existing client. Darren Indyke is the attorney for Jeffrey Epstein and an exisiting client. 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 Provide detailed and specific information. No Trust/Estate Other EFTA01481888 The source of wealth derives from distributions, funding from other sources - personal investments. Jeffrey Epstein (SSN: 090-44-3348 DOB: 01/20/1953 US Citizen) 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. Which country(ies) is(are) the Client's primary Source of Wealth or Income derived? Total Net Worth $ What was the total net worth based on? 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 has been asked to exit the firm by senior mgmt (John Duffy). This is now in progress for all of his accounts. Client has been asked to exit the firm - in progress. UNITED STATES 10000000.00 Financial Statements EFTA01481889 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? 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 Client has been asked to exit the firm - in progress. Client has been asked to exit the firm - in progress. Client has been asked to exit this firm - in progress. Client has been asked to exit the firm - in progress. Client has been asked to exit the firm - in progress. Client has been asked to exit the firm - in progress. Client has been asked to exit the firm - in progress. Yes Yes No Client activity related to exiting assets and accounts from JPM PB at request of sr mgmt. 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) EFTA01481890 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) ? Initial funding amount: 10,000,000 wire and the ongoing will come from his personal account at the 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 is to have a checking account for trust to pay any expenses the trust incurrs. 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.): Low monthy activity. Was expected activity for the client modified in the transaction activity section of the KYC ticket? Yes If modified, explain. Lowered the expected activity level. Additional Client Information Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.) This is another part of an existing client relationship with Jeffrey Epstein. The client has requested the opening of a checking account for trust. This trust is for the benefit of Jeffrey Epstein. Comment History Stage Name CEO Approval Approval History Stage Name Expected Activity Levels Low (1-10) Low (1-10) Low (1-10) Low (1-10) Low (1-10) Low (1-10) Anticipated Dollar Amount Totals per Month <$10,000 <$10,000 $10,000 TO $50,000 $10,000 TO $50,000 $50,001 TO $100,000 EFTA01481891 $50,001 TO $100,000 Creation Date Entered By 11/27/2013 11:03 AM JOHN R DUFFY Comment Preview approved to facilitate client exit Signoff Date Owner SID Owner Name EFTA01481892 Banker Attestation Market Manager Approval Regional Director Approval CEO Approval 10/30/2013 11:54 AM 11/26/2013 06:43 PM 11/27/2013 07:06 AM 11/27/2013 11:03 AM DF#@&T15#7@1 U095563 WILLIAM M SHERIDAN U005734 U963678 U093971 ALMA DEMETROPOLIS VINCENT A LA PADULA JOHN R DUFFY EFTA01481893