EFTA Document EFTA01582841

Tickett Client Name ECI LOB 103265268 Accounts TERRA MAR Account Title PROJECT. INC PB Account Type Initiated Date 04726/2012 03:39 PM Initiator DEBRA WHITE Initiating Team PEI FRONT OFFICE Verify & Confirm for TERRA MAR PROJECT, INC. Final Risk Rating Standard Initial Risk Rating High GCS Report Requested Full Presence of Potential High Risk Indicators No Reason for Adjustment Not associated with a HRJ. Derogatory information prewously . rressed Comments Summary of Risk Attributes Risk Updated History Creation Date Updated Risk Entered by Previous Comm ent Risk zii3C' S Grid; .•:. - • . ,,,,- ,•,.<„-,...::4„1,.. _, .;.<1. .,,s4e:,,.,;;;:::-':,./.> . Search Type Security Service Details Further Review Required Company Inlormahon Information not confirmed on Terra Mar Project Inc for lax Kr and address. Yes Corporate Records Information confirmed: details included in the attachment. No Other Database Searches iRDCIAIS/Factiva) No records were found. No Internal Database Search (CSSSFPS) Several newspaper articles detailing the investigation conducted by Belem 's Serious Fraud Office against Robert Maxwell He allegedly used pension funds to service debts. cover operating losses, gamble In the foreign exchange markets, and support the stock of his publicly held companies. The agency is also looking into a complaint from Swiss Bank Corp.. which says a did not receive collateral for a $100 million loan to a small private Maxwell company. Newspaper article dated 12.01)2000, which slated that 'Ghislaine Maxwell's source of wealth is being classified as something of o mystery.' Newspaper article dated 08,0911996 detailing the arrest of Ghislaine Maxwell on DNA charges. Numerous newspaper articles detailing the cnminal fraud charges broughl agairbst Kevin and Ian Maxwell (sons ol Robed Maxwell), Newspaper article dated 60212005 detailing Robed Maxwell nisaelfiferialed funds from the companies under his control. According to the newspaper article. 'He pledged assets as security for additional loans , but instead of delivering the assets to the lender, he would simply sell the assets for cash. 'For example. Bondi language school was supposedly sold to a Japanese publishing company. but the shares had previously been pledged as security for loans from Swiss Volksbank and Lehman Brothers.' Yes State Court Searches No records were found. No Federal Court Searches No records were found. No Personal Particulars No records were found. No Publications Publications revealed nothing derogatory. No Regulatory Sanctions No records were found. No OFAC/Control List Search A search of OFAC revealed no matches. No Negative or Inconsistent Information Yes GCS Red Dot Has this been identified as Red Dot KYC7 N !ative Information Found No No Confidential Treatment Requested by JPMorgan Chase JPM-SDNY-00062419 EFTA01582841