EFTA Document EFTA01482084

USCG Due Diligence Report - Individual DDR Name: Jeffrey Epstein — DDR Type: REVISED DDR Status: Process Banker Information Banker: Paul V Morris/JPMCHASE LE/OU: Banker SID: Banker BAC: Banker FNEN: Banker History: 03/04/2010 11:08:12 PM - CRD / Notrix JPMCHASE to Paul V Morris/JPMCHASE. 07/28/2006 11:00:04 PM - CRD / Notrix JPMCHASE to Mary C Casey/JPMCHASE. 07/15/2006 11:00:44 PM - CRD JPMCHASE to Jeffrey M Matusow/JPMCHASE. 07/10/2006 11:00:44 PM - CRD / Notrix JPMCHASE to Mary C Casey/JPMCHASE. 07/07/2006 11:00:21 PM - CRD / Notrix JPMCHASE to Robert Baynard/JPMCHASE. 06/24/2006 11:00:45 PM - CRD JPMCHASE to Jeffrey M Matusow/JPMCHASE. 01/19/2006 11:00:30 PM - CRD / Notrix JPMCHASE to Mary C Casey/JPMCHASE. 04/22/2005 10:10:28 PM - CRD / Notrix to U043917. DM ID Link Information The DM for this DDR is DM Name -JEFFREY The following DDR's are associated with DDR Name 116 East 65th St., LLC Darren K. Indyke PLLC Completed / Notrix / Notrix EMMCAC, LLC Epstein, Jeffrey Financial Trust Company, Inc. Financial Trust Company, Inc. Freedom Air International, Inc. HBRK Associates Inc. Hyperion Air, Inc. I-Correct.com LLC Indyke, Darren K Jege, Inc. LYN & JOJO LLC changed: changed: changed: changed: changed: changed: changed: changed: Banker from Mary C Casey/- Banker from Jeffrey M Matusow/- Banker from Mary C Casey/- Banker from Robert Baynard/- Banker from Jeffrey M Matusow/- Banker from Mary C Casey/- Banker from Mary Rieth/- Banker GID from 00000043917 E EPSTEIN CAS ID - 9710670708. this Decision Maker . EFTA01482084 MAX Foundation New York Strategy Group, LLC Plan D, Inc. The 2007 Jeffrey E Epstein Insurance Trust #2 - November 1, 2007 The 2007 Jeffrey E Epstein Insurance Trust #3 dtd November 1, 2007 The 2007 Jeffrey E. Epstein Insurance Trust #1 Dtd November 1, 2007 The C.O.U.Q. Foundation, Inc. The Haze Trust Name/Contact Information Banker Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Security Services Search Date 02/02/2009 10/17/2008 02/08/2004 08/06/2004 03/07/2011 08/11/1999 05/21/2003 03/11/2010 10/17/2008 02/03/2009 01/30/2009 01/15/2010 02/03/2009 07/31/2006 EFTA01482085 02/08/2004 12/10/2009 04/16/2003 01/30/2009 12/01/2008 12/02/2008 11/25/2008 01/28/2004 102/29338 N256838 8634--CHBG 01 JPMC Internal Use Only EFTA01482086 Is this DDR being used for multiple entities? Last Name: First Name: Middle Name/Initial: Previous Last Name(s): Title: Business Name: J. Epstein & Co. (To Record Individual's Ownership Or Employer) Primary Address Addresses (Legal address on account) Name: Attention: Address Line 1: Address Line 2: City: State: Province: Postal/Zip Code: Country: Legal Entity: Industry Code: Citizenship: Date of Birth: Gender: Tax ID # : Passport/Drivers License #: Home Phone: ()Introduction Information Introduction Type: Specific Information: Met With Principal? If you did not meet the Principal, give an indication of why you haven't met the individual and when you will. N/A What form of goverment issued identification document did you obtain for the files? Driver's License Financial Information Other Jeffrey Epstein is an existing client. 10065 USA UNITED STATES Jeffrey Epstein c/o HBRK Associates 301 East 66th Street, Suite 10B New York EFTA01482087 NY (Other than Primary Address) Business Address Epstein Jeffrey Individual / Joint PRIVATE HOUSEHOLDS NAIC Code: 814100 USA 01/20/1953 (Use 4-digit year) Male Remember to collect W-8's or other applicable tax forms for each jurisdiction. EFTA01482088 Occupation, Business or Employer of the Client: Net Worth of Client: Documentation/ Information obtained to confirm stated net worth of the Client: Source Of Wealth: Please Describe: Money manager $ 300 (USD millions) accounts held at JPM, knowledge of ownership of certain assets, and public articles Other Epstein has made his wealth managing money for wealthy individuals Other (Provide detailed and specific information) Epstein managed money for wealthy individuals, most notably Leslie Wexner until 02/08. Transaction Profile/Expected Account Activity What is the purpose/intended use of this account? Operational/household checking accounts and custody account to hold money market funds. Please select each "Product Type" that applies. Within each product type, please check ALL transaction types that apply and provide a description of expected account activity. (document expected sources of inflows and destinations of transfers,countries, and types of payors/payees.Include where is the money coming from - example : A specific bank or firm and purpose of specific transactions, if known) Product Type - Select all that apply Transaction Types - Select all that apply and expected activity level ( L = 1-5, M = 6-12, H =>12 transactions per month) Deposit/Current Accounts (Checking, Savings, Money Market) Cash ( withdrawals/deposits) - Check deposits / Check paid - Wire Incoming & Outgoing Internal Transfers Other Please describe in detail expected account activity for this product : Account is used for maintenance of his various homes and lifestyle expenses; EFTA01482089 not unusual for the client to pull cash out up to $50K. Personal accts. are primarily funded from Mr. Epstein's personal investment entity (which invests mostly in JPM MM Funds). Investment Products (Custody, Brokerage,Agency,Margin) Cash ( withdrawals/deposits)Check deposits / Check paid - Wire Incoming & Outgoing - Internal Transfers Purchase & Sells Anticipated $ Amount Totals per month — Please provide at least an estimate $10000 to $25000 $500000 to $1MM $1MM to $5MM $1MM to $5MM Below $1MM $1MM to $5MM EFTA01482090 Other Please describe in detail expected account activity for this product : Fiduciary (Investment Mgmt. / Trust) Custody account currently holds a money market fund. Credit type facilities (Line of Credit, Mortgage, Letter of Credit) Required Security Services Checks Security Search Type: Note for Security Services: Please list any specific search requests/instructions to Security Services here Security Services Information A Security Services Check is REQUIRED for New Clients and Prospects This section to be completed by the Security Services Group: List Individuals and Corporate Entities Investigated: Attachment: Please Note: All research is subject to the availability of electronic database resources. Full Please update with any new information since the last search was conducted. Please include all information as this will be the primary DDR that will be used for annual review for Jeffrey Epstein. Search Type Is Security Service Details: Further Review by Banker Require d? Company Information No Information not confirmed; details included in the attachment. Reference section of the DDR titled "Red Dot (derogatory information) identified:" to view the specifics on the adverse information GS&I has identified for this account Corporate Records Other Database Searches (RDC/CDC/MIS) No No No records were found. No RDC/CDC/MIS records were found. EFTA01482091 Sex Offender: Information confirmed; details included in the attachment. CSSS: Information confirmed; details included in the attachment. Reference section of the DDR titled "Red Dot (derogatory information) identified:" to view the specifics on the adverse information GS&I has identified for this account. Civil Court Action Federal & State Court Action Personal Particulars Publications No No No No No records were found. No records were found. No additional research necessary. Information confirmed; details included in the attachment. Reference section of the DDR titled "Red Dot (derogatory information) identified:" to view the specifics on the adverse information GS&I has identified for this account. Regulatory Sanctions No No records were found. Banker Response: EFTA01482092 OFAC/Control List Search No No records were found. Has this been identified as a Red Dot DDR? : Red Dot (derogatory information) Identified: Red Dot information is any derogatory information identified by Global Security Services which warrants the attention of the banker. The presence of "Red Dot" information does not necessarily mean that an existing relationship will be exited or a potential client relationship not pursued. The banker should document any conversations that have taken place with the client/prospect, if any, with regard of the issue and whether or not this impacts his/her, or management's decision to continue with or accept the person/entity as a client. Security Service Details (Include DDR names in which this was previously reported, if any) Proceed with or maintain the client relationship Yes / No Banker Response (If "Yes", please provide your rationale for proceeding with or maintaining the client relationship. If "No", please specify steps that will be taken) The following information was previously reported to Mary C Casey on 09/21/2006 under the account YHS, LLC (DDR # 7391/06): 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. As of 3/4/2011: 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. MC2 Model Management received $1 million from Epstein in 2005. It is unknown if the money was given as a secret investment or payment for services as a procurer. Jean Luc Brunel, owner of MC2 Model Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children for sexual play for money. In addition, Brunel was a frequent passenger on Epstein's private jet and often visited Epstein in jail. MC2 Model Management was issued a citation by the Florida Business and Professional Regulation for acting EFTA01482093 as a talent agent without a license. MC2 Model Management LLC has two outstanding federal tax liens totaling $593,789 ($443,728 + $150,061). Expense No.: Total Costs: Signed by: Dated: 99/137001 $0.00 Ashish S Patel 03/07/2011 01:25:02 PM As per internal discussions Individual Checks Date Comments Background Check (Required If Check Carried Out) 02/12/2009 (Required If Check Carried Out) Jeffrey Epstein is an existing client of PB. In years past, he was an active brokerage client, particularly foreign EFTA01482094 exchange, and as of this year he is a custody-only client. Formerly, Jeffrey Epstein was a money manager for high net individuals, most notably Leslie Wexner. Wexner was a JPM client and then retained Epstein as his advisor 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. The purpose of this DDR is to refresh our due diligence on Mr. Epstein. 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. Summary Summary Of Findings: 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. Mr. Wexner terminated his relationship with Epstein in 02/2008. Mr. Epstein is well known to several JPM PB employees and to Jes Staley. Mr. Epstein was convicted of a felony charge in 2008 and was to serve an 18-month prison sentence. Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a client. 6-18-10: Mr. Epstein is currently serving out his house arrest. Our view is that Mr. Epstein has served his time and completing his duties to society. We are assessing the situation closely and monitoring the occassional news stories regarding Mr. Epstein and civil lawsuits. 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. Anticipated Product(s) Custody Deposits EFTA01482095 Number Assignments Standalone Entity? If this legal entity is or will be a Client (PCN) or Prospect answer YES. If this legal entity is or will be part of an Existing PCN relationship answer NO. If "No" above, then indicate the Client (PCN): Ultimate Customer Number (UCN): Optionally, you may indicate the Affiliation Number: SPN Required? SPN#: 1405152 CAS ID: 9710670708 1405152 9710670708 EFTA01482096 Approval Information Public/High Profile Figure Yes If a Public/High Profile figure, please select one of the following: Other If other please describe: Convicted Felon Public/High Profile Figures: Explain the individual's position as/association with a senior political official/prominent person High Risk Jurisdiction High Risk Business Banker: LE/OU: Senior Manager: Area Head: No No Paul V Morris/JPMCHASE 102/29338 Marcus Sheridan/JPMCHASE Catherine Keating/JPMCHASE Annual / Periodic Review Information Annual/Periodic Review Due in: 12 months This annual/periodic review is for DMID # 9710670708 - DMID Name: JEFFREY E EPSTEIN The actual review is being conducted within the Ranch Lake III, Inc. DDR. Banker Approval Information Sponsorship affirmation - Based on my due diligence and the information provided , I approve and accept sponsorship of Jeffrey Epstein — as a Client from inception and throughout the client relationship. Paul V Morris 03/07/2011 02:37:45 PM Senior Manager Approval Information Based on the information provided and the approval granted by Paul V Morris, I approve the acceptance of Jeffrey Epstein — as a Client. Marcus Sheridan 03/29/2011 10:44:53 AM Area Head Approval Information Based on the information provided and the approval granted by Paul V Morris and Marcus Sheridan, I approve the acceptance of Jeffrey Epstein — as a Client Catherine Keating 04/14/2011 04:55:58 PM Quality Reviewer Information 1st Quality Review Comment: 2nd Quality Review Comment: 3rd Quality Review Comment: Bonnie K Perry on 1/12/2009 10:23:42 AM Comments : Ok to approve. EFTA01482097 Bonnie K Perry on 6/9/2010 2:42:34 PM Comments : DDR needs to include more up to date information as to Mr. Epstein's current circumstances. Bonnie K Perry on 6/28/2010 1:42:40 PM Comments : Exceptions have been addressed. Review of account activity did not reveal anything out of the ordinary. EFTA01482098 Personal accounts are typically funded from Jeffrey Epstein's investment entity and then Mr. Epstein disburses money to various other accounts used in support of his homes, legal fees, insurance, etc. Ok to approve. 4th Quality Review Comment: 5th Quality Review Comment: Admin Comments Admin Comments: By: Date: Admin Comments History : Document History Created: 05/12/2003 Last Modified: 04/14/2011 Submitted: 03/29/2011 10:44:53 AM Audit History 38. 'Area Head Approval' performed by: Catherine Keating on: 04/14/2011 04:56:13 PM 37. Quality Review performed by: Bonnie K Perry on: 04/01/2011 05:22:48 PM 36. 'Senior Manager Approval' performed by: Marcus Sheridan on: 03/29/2011 10:44:53 AM 35. Button: 'Change Senior Manager' performed by: Bonnie K Perry on: 03/07/2011 04:31:17 PM 34. 'Banker Approval' performed by: Paul V Morris on: 03/07/2011 02:37:48 PM 33. Submitted for Banker Approval SS Type = Full performed by: Ashish S Patel on: 03/07/2011 01:25:05 PM 32. Changed DDR Status from: Awaiting Banker Approval to Awaiting Security Services Research performed by: Mary E Meisner on: 03/07/2011 12:07:48 PM 31. Submitted for Banker Approval SS Type = Full performed by: John J O'reilly on: 03/04/2011 04:30:08 PM 30. Button: 'Flag: Security Check has begun' performed by: John J O'reilly on: 03/04/2011 04:29:39 PM 29. Button: 'Print' performed by: Ligaya X Felismino-Stesner on: 02/22/2011 04:10:12 PM 28. Submitted for Security Services Approval performed by: Paul V Morris on: 02/22/2011 02:35:45 PM 27. Button : 'Update/Revise DDR' performed by: Paul V Morris on: 02/22/2011 02:21:53 PM 26. Area Head Approved on Behalf of Catherine Keating because designated Area Head is Confirmed with Catherine on 7/9/10 performed by: Dustin F Kennedy on: 07/09/2010 03:00:18 PM 25. Quality Review performed by: Bonnie K Perry on: 06/28/2010 01:42:58 PM 24. Changed DDR Status from: Awaiting Banker Approval to Awaiting Area Head Approval performed by: Bonnie K Perry on: 06/28/2010 01:38:01 PM 23. Changed DDR Status from: Awaiting Area Head Approval to Awaiting Banker Approval performed by: Bonnie K Perry on: 06/28/2010 01:32:45 PM 22. 'Senior Manager Approval' performed by: Mary C Casey on: 06/18/2010 EFTA01482099 12:57:11 PM 21. 'Banker Approval' performed by: Paul V Morris on: 06/18/2010 12:11:19 PM 20. Changed DDR Status from: Awaiting Senior Manager Approval to Awaiting Banker Approval performed by: Bonnie K Perry on: 06/09/2010 03:05:18 PM 19. Quality Review performed by: Bonnie K Perry on: 06/09/2010 02:42:42 PM 18. 'Banker Approval' performed by: Paul V Morris on: 06/08/2010 01:34:50 PM 17. Submitted for Banker Approval SS Type = Full performed by: Viktoriya X Ignatenko on: 04/16/2010 10:12:12 AM 16. Button: 'Print' performed by: Javia S Hairston on: 04/12/2010 10:39:27 AM 15. Submitted for Security Services Approval performed by: Bonnie K Perry on: 04/09/2010 06:17:44 PM 14. Button : 'Update/Revise DDR' performed by: Bonnie K Perry on: 04/09/2010 06:14:18 PM 13. 'Area Head Approval' performed by: Catherine Keating on: 02/24/2009 09:02:12 AM 12. 'Senior Manager Approval' performed by: Marcus Sheridan on: 02/12/2009 06:31:53 PM 11. 'Banker Approval' performed by: Mary C Casey on: 02/12/2009 01:26:59 PM 10. Changed DDR Status from: Awaiting Area Head Approval to Awaiting Banker Approval performed by: James Dalessio on: 01/12/2009 03:40:22 PM 9. Quality Review performed by: Bonnie K Perry on: 01/12/2009 10:23:52 AM 8. 'Senior Manager Approval' performed by: Marcus Sheridan on: 12/16/2008 12:58:02 PM 7. 'Banker Approval' performed by: Mary C Casey on: 12/12/2008 12:40:38 PM 6. Submitted for Banker Approval SS Type = Full performed by: Matthew P Hynson on: 12/10/2008 02:06:23 PM 5. Button: 'Flag: Security Check has begun' performed by: Ligaya X Felismino- Stesner on: 12/02/2008 02:20:42 PM 4. Button: 'Print' performed by: Ligaya X Felismino-Stesner on: 12/02/2008 02:18:15 PM 3. Submitted for Security Services Approval performed by: Mary C Casey on: 12/02/2008 01:58:52 PM 2. High Risk Business set to 'No' because Epstein is a high profile/- controversial figure (as noted) but does not run a high risk business. - performed by: Mary C Casey on: 12/02/2008 01:56:23 PM 1. Button : 'Update/Revise DDR' performed by: Mary C Casey on: 12/02/2008 11:58:59 AM Converted Tracking Document History: 1. Client Manager Approval by: Mary Rieth on 05/28/2003 08:34:02 AM. 2. Senior Manager Approval by: Tad C Smith on 05/28/2003 09:04:12 AM. 3. Awaiting Security Services Research by: Mary Rieth on 05/14/2003 11:15:48 AM. 4. Security Services Sign-Off by: Vanessa A Budhu on 05/21/2003 10:25:48 AM. DDR would not allow annual review. There is an error message that another DDR within the relationship is already undergoing annual review, therefore this DDR did not produce an annual review alert in February as it should have. Bonnie K Perry/JPMCHASE EFTA01482100 04/09/2010 06:19:17 PM Bonnie K Perry on 4/1/2011 5:22:43 PM Comments : DDR was updated to include additional information with regard of the client's situation. Accts are being closely monitored by AML Ops. By: Mary Rieth By: Catherine Keating By: Marcus Sheridan EFTA01482101 CN=Ujwala Srinath/O=JPMCHASE: Relatiohship Activity Summary Jeffrey Epstein - 9710670708 - 2010.pdf CN=Ujwala Srinath/O=JPMCHASE: 1309811B.doc CN=Ujwala Srinath/O=JPMCHASE: 2065010B.doc CN=Ujwala Srinath/O=JPMCHASE: 1137404B.doc CN=Ujwala Srinath/O=JPMCHASE: 210203B.doc CN=Ujwala Srinath/O=JPMCHASE: 739106B.doc CN=Ujwala Srinath/O=JPMCHASE: 742010B.doc CN=Ujwala Srinath/O=JPMCHASE: 100710086.doc CN=Ujwala Srinath/O=JPMCHASE: STG04444 000HHHppp eLink$Source @' @ EFTA01482102