EFTA Document EFTA01481925

Ticket# 102657535 Client Name ECI LOB JEEPERS, INC. 0241857215 PB Account# Account Title Account Type Initiated Date Initiator Initiating Team 12/08/2011 11:53 AM DEBRA WHITE PB FRONT OFFICE Verify & Confirm for JEEPERS, 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) Full No Derogatory information - Jeffrey Epstein personally is flagged as High Risk due to felony conviction. Moderate High Updated Risk Previous Risk Comment Security Service Details No records were found. Further Review Required No No additional research necessary. No records were found. Internal database search revealed prior GS&I research for Jeffrey E 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. EFTA01481925 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 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 Yes No Yes No additional research necessary. No additional research necessary. No additional research necessary. No records were found. No No No Publications revealed nothing derogatory. No No records were found. No No Yes No No Yes Long standing clent reviewed regualrly by compliance and management. Research continue to reveal inforamtion on Jeffrey Epstein and felony conviction. No additional news to report. EFTA01481926 Primary Information Client Type Client Status Confidential Names? Legal Business Name Country of Primary Domicile 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? Non Individual Client No Front Office Restricted? Active Indicator JEEPERS, INC. VIRGIN ISLANDS, U.S. Primary Country of Assets VIRGIN ISLANDS, U.S. VIRGIN ISLANDS, U.S. Personal Investment Companies (525997] Corporation 08/18/2003 Corporation - Certified Articles of Incorporation Investments Is the entity a Personal Holding Company (PHC) or Personal Investment Company (PIC) located in an offshore jurisdiction? PHC/PIC Questions Are shares registered or in bearer form List the total number of shares that have been issued High Risk Jurisdiction Address(es) Type Legal Notes Address 6100 RED HOOK QUARTER B3 Phone(s)/Fax(s) Type Work Notes Phone Number 3407752523 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 EFTA01481927 GIO Trust Advisor Decision Maker Identification Withholding Federal Status Domestic Certified Withholding SSN/TIN Certification Date 12/08/2011 Email Entered by Date of Update Preferred Entered by SYSTEM Date of Update 12/08/2011 Preferred Yes City, State, Postal Code ST. THOMAS, 00802 Country Tools Map it Entered by Date of Update BATCH Preferred 12/08/2011 Yes Registered 1000.0 Yes What is the authorized capital(This information is usually found in the Board Resolution and/or minutes) 1000.0 Yes WebSite Organization State Secondary Industry Code (NAIC) Client Category Profit Insider Code (Reg. 0) Normal Client Client Type PAUL V MORRIS 008634 - CHBG 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 EFTA01481928 SSN/TIN/EIN 66-0629193 Introduction & Wealth Introduction Type Net Worth of client($) Additional Entities No additional entities available at this time Additional Party Information ECI Party Type Party Name Last Completed Search Date 9710670708 Individual Jeffrey E Epstein 03/07/2011 KYC Status Report Type Relation Type In Progress Full Sole Owner Powers Percent Owned 100.0 Existing JPMorgan Client - Inside LOB 50,000,000.00 Primary Information for Jeffrey E Epstein Client Type Client Status Front Office Restricted? Confidential Names? First Name Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Individual Client Normal No Country of Primary Domicile UNITED STATES Prefix/Title Jeffrey E Epstein UNITED STATES High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Legal Notes Address ATTN DARREN K INDYKE, 301 EAST 66TH STREET, SUITE 10B, Phone(s)/Fax(s) Type Home Notes Phone Number Tools EFTA01481929 2127509790 Verify "Do Not Call" List Email(s) Type Notes Email address not available Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team Email Entered by Date of Update Preferred Entered by BATCH Date of Update Preferred 05/12/2011 Yes City, State, Postal Code NEW YORK, New York, 10065 Country UNITED STATES Tools Map it Entered by Date of Update BATCH Preferred 09/08/2007 Yes INDIVIDUALS (999940) Personal Investment Companies (525997) Generation Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets Jeffrey E Epstein Male 01/20/1953 UNITED STATES Yes Single Client Client Type PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 Entity Type Decision Maker Individual EFTA01481930 Identification Withholding Federal Status Form of government issued identification obtained for files Primary Identification Number Date Issued Introduction & Wealth Introduction Type Net Worth of client($) Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth following list of options Issued By Expiration Date Withholding SSN/TIN Certification Date SSN/TIN/EIN 090443348 Introduction Non Individual For Profit? Locations Served? a. If International or both, please describe: Corporation - For Profit Yes Both To conduct its business in the Virgin Islands and elsewhere in the United States and foreign countries and to have offices within or outside the Virgin Islands and to hold, purchase, mortgage and convey real and personal property within or outside the Virgin Island. Public or Private Are beneficial owners/principal shareholders associated this business? Who owns this entity? Please Provide ownership details Private Yes Individual Jeffrey Epstein is the Jeffrey Epstein DOB: SSN: Citizen: Unite States Govt ID: US Virgin Islands Expires - 1/20/2015 Ownership is not equal to 100%? Are there any authorized signers 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 No No JPMC Network 12/08/2011 This is another Epstein. An ECI was created for this entity in the Retail Bank but no account number was ever assigned. We are moving this ECI from Retail to Private Bank to open an asset/brokerage account. 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 Entity Type part of an the sole owner of the corporation - - CI 0000025874 with - Issued 1/15/2010 or any other from individuals existing client relationship with Jeffrey EFTA01481931 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. Which country(ies) is(are) the Client's primary Source of Wealth or Income derived? Is this an Operating Company? No For Profit Other The source of wealth will derive from the personal assets of Jeff Epstein. Jeff Epstein is self-employed investor/entrepreneur. UNITED STATES No EFTA01481932 Total Net Worth $ 50000000.00 What was the total net worth based on? 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? Is the PHC/PIC managed by JPMC? (Trustees of the entity are JPMC employees, e.g., PHC managed in Nassau/Geneva/Delaware) PHC/PIC Location Did the client confirm with you that the beneficial ownership is as stated within this KYC? Did the client confirm that he/she would inform you if beneficial ownership changes? Was the "Confirmation of Beneficial Ownership" document received from the beneficial owner? Please attach the J.P. Morgan Confirmation of Beneficial Ownership document to the KYC. List the number of shares that have been issued 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? Additional Comments Expected Activity Client Directed Asset / Brokerage 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) <$10,000 What is the initial/ongoing source of funding for the client's Client Directed Asset / Br okerage Account(s) ? The initial source of funding will be from an external wire tranfer of funds from First B EFTA01481933 ank Virgin Islands Bank in the amount of $800. Any ongoing source of funding will also be from First Bank Virgin Islands Bank. 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. The purpose of the account is to purchase securities for future wealth accummulation. Low (1-10) <$10,000 Expected Activity Levels Anticipated Dollar Amount Totals per Month Client well-known to PB team and regularly reviewed at reputational risk meeting and updates. Long standing PB client. Integrated team/management team >$100 million No N/A 1000.00 Financial Statements No No No No aa. None of the above Yes No Have you received copies of the shares or listing of shares? Yes Are the shares registered or in bearer form? Registered VIRGIN ISLANDS, U.S. Yes Yes Yes EFTA01481934 Additional Client Information Please include any additional information that would further explain your knowledge of th e client (family tree/history, public information, websites, etc.) Comment History Stage Name Creation Date Entered By There are no comments entered at this time. Approval History Stage Name Banker Attestation Market Manager Approval Regional Director Approval Comment Preview Signoff Date 04/19/2012 11:00 AM 04/20/2012 06:13 PM 04/30/2012 01:06 PM DFMT1547@1 Owner SID N256838 U043917 U095563 Owner Name PAUL V MORRIS MARY C CASEY WILLIAM M SHERIDAN EFTA01481935