EFTA Document EFTA01481957

Ticket# 102745698 Client Name ECI LOB NEPTUNE LLC 0391309309 PB Account# Account Title Account Type Initiated Date Initiator Initiating Team 01/03/2012 10:50 AM ELIZABETH M CAMPBELL PB FRONT OFFICE Verify & Confirm for NEPTUNE LLC Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators 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) High High Full No Updated Risk Previous Risk Comment Security Service Details Information not confirmed for Neptune LLC; details included in the attachment. (TAX ID and Address) EFTA01481957 Information confirmed; details included in the attachment. 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. 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 No No records were found. No records were found. No additional research necessary. No records were found. EFTA01481958 No No No Publications revealed nothing derogatory. No No records were found. No No Yes Further Review Required Yes No No Yes exisitng client of the Private Bank. regularly reviewed by management and risk committee. EFTA01481959 Primary Information Client Type Client Status Confidential Names? Legal Business Name Non Individual Client No Front Office Restricted? Active Indicator NEPTUNE LLC Country of Primary Domicile UNITED STATES Primary Country of Assets Country of Organization Industry Code (NAIC) UNITED STATES UNITED STATES LESSORS OF OTHER REAL ESTATE PROPERTY [531190] 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 301 E 66TH ST APT 1OF City, State, Postal Code NEW YORK, New York, 100656216 Phone(s)/Fax(s) Type Work Notes Phone Number 6464147584 Tools Verify "Do Not Call" List Email(s) Type EFTA01481960 Work Notes Email richardkahn12@gma il.com 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 Net Worth of client($) Additional Entities No additional entities available at this time 12/28/2011 45-4093384 Entered by BATCH Date of Update Preferred 01/03/2012 Yes Entered by SYSTEM Date of Update 01/03/2012 Preferred Yes Country UNITED STATES Tools Map it Entered by Date of Update BATCH Preferred 01/03/2012 Yes Limited Liability Company 12/21/2011 LLC - State Certificate EFTA01481961 A household account to pay expenses for property upkeep and maintenance Yes Is the entity a Personal 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 Profit Delaware Normal Yes Florida 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 Existing JPMorgan Client - Inside LOB 300,000,000.00 EFTA01481962 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 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 High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Legal Notes Address ATTN DARREN K EFTA01481963 INDYKE, 301 EAST 66TH STREET, SUITE 108, Phone(s)/Fax(s) Type Home Notes Phone Number Tools 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 Identification Withholding Federal Status Form of government issued identification obtained for the files Date Issued Drivers License Primary Identification Number 0000025874 01/15/2010 Introduction & Wealth Issued By Expiration Date VIRGIN ISLANDS, U.S. 01/20/2015 Withholding SSN/TIN Certification Date SSN/TIN/EIN 090443348 Email Entered by Date of Update Preferred Entered by BATCH Date of Update Preferred 05/12/2011 Yes City, State, Postal Code NEW YORK, EFTA01481964 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 EFTA01481965 Introduction Type Net Worth of client($) 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 0390552637 Individual HARRY BELLER Primary Information for HARRY BELLER Client Type Client Status Front Office Restricted? Prefix/Title First Name Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Individual Client Normal Confidential Names? Country of Primary Domicile UNITED STATES HARRY BELLER KYC Status Report Type Relation Type Full Signer Powers Full Percent Owned 0.0 Generation Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets EFTA01481966 High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Work Notes Address 301 E 66TH ST APT 108, Phone(s)/Fax(s) Type Work Notes Phone Number Tools 6468624817 Verify "Do Not Call" List Email(s) Type Work Notes Email harrybeller@gmail.c om 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 Drivers License Primary Identification Number 628679340 05/09/1956 Issued By Expiration Date UNITED STATES New York 05/09/2019 Withholding SSN/TIN Certification Date SSN/TIN/EIN 081520727 Entered by EFTA01481967 ROSALIA CRACCHIOLO Date of Update 05/12/2011 Preferred Yes Entered by SYSTEM Date of Update Preferred 05/12/2011 Yes City, State, Postal Code NEW YORK, New York, 100656298 Country UNITED STATES Tools Map it Entered by Date of Update SYSTEM Preferred 05/12/2011 Yes HARRY BELLER Male 05/09/1956 Yes Single Client Client Type 118313 - IVT OT CENTER Entity Type Individual EFTA01481968 Introduction & Wealth Introduction Type Net Worth of client($) Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth from following list of options ECI Party Type Party Name Last Completed Search Date 0244658617 Individual JANUSZ BANASIAK Primary Information for JANUSZ BANASIAK Client Type Client Status Front Office Restricted? Confidential Names? First Name Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Individual Prospect Normal No Country of Primary Domicile UNITED STATES Prefix/Title JANUSZ BANASIAK UNITED STATES High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Home Notes Address 358 EL BRILLO WAY„ City, State, Postal Code PALM EFTA01481969 BEACH, Florida, 334804730 Phone(s)/Fax(s) Type Other Notes Phone Number Tools 2127509790 Verify "Do Not Call" List Email(s) Type Notes Email address not available Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team Identification Withholding Federal Status Domestic not certified SSN/TIN/EIN 096-64-8809 Email Entered by Date of Update Preferred Entered by SYSTEM Date of Update Preferred 01/04/2012 Yes Country UNITED STATES Tools Map it Entered by Date of Update ELIZABETH M CAMPBELL Preferred 01/04/2012 Yes INDIVIDUALS [999940] Other KYC Status Report Type Relation Type Full EFTA01481970 Signer Powers Administrativ e Percent Owned 0.0 Generation Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets Florida JANUSZ BANASIAK Male 04/07/1953 UNITED STATES Prospect Client Type PAUL V MORRIS 008634 - CHBG Entity Type Individual EFTA01481971 Form of government issued identification obtained for the files Date Issued Introduction & Wealth Introduction Type Net Worth of client($) Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth from following list of options Drivers License Primary Identification Number 8522420531270 08/09/2005 Issued By Expiration Date UNITED STATES Florida 04/07/2012 Introduction Non Individual Entity Type For Profit? Locations Served? 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 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 Limited Liability Company - For Profit Yes Domestic EFTA01481972 No Individual Jeffrey E. Epstein is the sole owner of this account. No Yes JPMC Network 01/03/2012 Mr. Jeffrey Epstein is an exiting client of the Private Bank. For Profit Other Jeffrey Epstein is an existing client of PB. In years past, he was an active brokerage client. Formerly, Jeffrey Epstein was a money manager for high net worth individuals, most notably Leslie Wexner. Wexner was a JPM client and then retained Epstein as his advisor in the late 90s. 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? a. Please describe: 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.) UNITED STATES No 300000000.00 Other Jeffrey Epstein is an existing client of the Private Bank No No No EFTA01481973 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? 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 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) What is the initial/ongoing source of funding for the client's Deposit Account(s) ? Initial source of funding of $100 K will be debited from the JPM DDA # 739110438 — Jeffrey Epstein. This will be an internal transfer. Ongoing source of funding will continue to come from A/C # 739110438 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. Household expenses at the 358 El Brillo Way, Palm Beach FL 33480 property. Additional Client Information Please include any additional information that would further explain your EFTA01481974 knowledge of the client (family tree/history, public information, websites, etc.) $50,001 TO $100,000 Expected Activity Levels Low (1-10) Low (1-10) Low (1-10) Low (1-10) Anticipated Dollar Amount Totals per Month <$10,000 <$10,000 <$10,000 <$10,000 regularly reviewed by management/reputational risk committee. Long serving client relationship w/ the Private Bank. Integrated tea/senior management. Primarily investments, >$100 million. No. N/A No aa. None of the above No 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 CEO Approval Comment Preview Signoff Date 03/08/2012 04:08 PM 03/16/2012 09:46 AM 03/19/2012 02:33 PM 03/28/2012 05:54 PM Owner SID N256838 U043917 U095563 U234588 EFTA01481975 Owner Name PAUL V MORRIS MARY C CASEY WILLIAM M SHERIDAN BONNIE K PERRY EFTA01481976 DF#@&T15#7@1 EFTA01481977