EFTA Document EFTA01594097

Ticket#: Client Name: ECI#: LOB: 102238622 ELLMAX 0033845033 PB Account#: Account Title: Account Type: Initiated Date#: Initiator: Initiating Team: 08/22/2011 11:20 AM DEBRA WHITE PB FRONT OFFICE Verify and Confirm for ELLMAX Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators Standard Standard Full No GCS Grid Search Type Security Service Details Company Information Corporate Records Other Database Searches (RDC/MIS/Factiva) Internal Database Search (CSSS/FPS) Information not confirmed for Ellmax (Tax ID). Details included in the attachment. Information confirmed; details included in the attachment. No records were found. Internal database search revealed prior GSI research and the following derogatory information was reported: Several newspaper articles detailing the investigation conducted by Britains 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 it did not receive collateral for a $100 million loan to a small private Maxwell company. Newspaper article dated 12/01/2000, which stated that Ghislaine Maxwells source of wealth is being classified as something of a mystery. Newspaper article dated 08/09/1996 detailing the arrest of Ghislaine Maxwell on DWI charges. Numerous newspaper articles detailing the criminal EFTA01594097 fraud charges brought against Kevin and Ian Maxwell (sons of Robert Maxwell). Newspaper article dated 6/23/2005 detailing Robert Maxwell misappropriated 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, Berlitz 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." State Court Searches Federal Court Searches Personal Particulars Publications Regulatory Sanctions OFAC/Control List Search Negative or Inconsistent Information No records were found. No records were found. No additional research necessary. No records were found. No records were found. A search of OFAC did not reveal any matches. Further Review Required Yes No No Yes No No No No No No Yes GCS Red Dot EFTA01594098 Has this been identified as Red Dot KYC? Negative Information Found No Yes 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 Existing relationhsip Reviewed Primary Information Client Type Client Status Confidential Name? Legal Business Name Country of Primary Domicile Primary Country of Assets 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? High Risk Jurisdiction Non Individual Client No ELLMAX UNITED STATES UNITED STATES UNITED STATES ADMIN & GENERAL MGT CONSULTING SERVICES [541611] Limited Liability Company 12/16/2010 LLC - State Certificate The nature/purpose of the entity is consulting peronnel recruitment No Is the entity a Personal Holding Company (PHC) or Personal Investment Company EFTA01594099 (PIC) located in an offshore jurisdiction? No Front Office Restricted? Active Indicator Insider Code (Reg. 0) Primary Domicile State WebSite Organization State Secondary Industry Code (NAIC) Client Category Profit Florida Normal Yes Florida Address(es) Type Legal Notes Address 16 ISLAND AVENUE - #7D City, State, Postal Code MIAMI, Florida, 33139 Country Tools UNITED STATES Map it Entered by BATCH Date of Update Preferred 08/23/2011 Yes Phone(s)/Fax(s) Type Work Notes Phone Number 2125356833 Tools Verify "Do Not Call" List Entered by SYSTEM Date of Update 08/22/2011 Preferred Yes EFTA01594100 Email(s) Type Email address not available Notes Email Entered by Date of Update Preferred Cost Center & Hierarchy Client Status Client Client Sponsor Cost Center Client Service Team GIO Trust Advisor Decision Maker DM ECI PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 Ian E Hirschfield GHISLAINE MAXWELL 0106585908 Client Type New or Existing Client Entity Type Portfolio Manger Investor Non Individual Existing Entity Identification Withholding Federal Status Domestic Certified Withholding SSN/TIN Certification Date SSN/TIN/EIN 08/22/2011 Introduction & Wealth Introduction Type Net Worth of client($) Existing JPMorgan Client - Inside LOB 30,000,000.00 ECI Additional Party Information Party Type 0106585908 Individual Party Name Ghislaine Maxwell EFTA01594101 Last Completed Search Date 03/31/2005 KYC Status Completed Report Type Full Relation Type Owner Powers Percent Owned 100.00 Primary Information for Ghislaine Maxwell Client Type Client Status Front Office Restricted? Confidential Name? Country of Primary Domicile Individual Client Normal No UNITED STATES Generation Active Indicator Marital Status Yes EFTA01594102 Prefix/Title First Name Ghislaine Middle Name Last Name Suffix Previous Name/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Maxwell UNITED STATES High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets 01/01/1901 UNITED STATES Ghislaine Maxwell Address(es) Type Legal Notes Address 16 ISLAND AVE APT 7D„ City, State, Postal Code MIAMI BEACH, Florida, 331391331 Country Tools UNITED STATES Map it Entered by SYSTEM Date of Update Preferred 03/22/2011 Yes Phone(s)/Fax(s) Type Home Notes Phone Number Tools Verify "Do Not Call" List EFTA01594103 Entered by SYSTEM Date of Update 03/22/2011 Preferred Yes Email(s) Type Home Notes Email Entered by SYSTEM Date of Update 03/22/2011 Preferred Yes Cost Center & Hierarchy Client Status Client Client Sponsor Cost Center Client Service Team PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 Entity Type Decision Maker Client Type Individual Identification Withholding Federal Status EFTA01594104 Introduction & Wealth Introduction Type Net Worth of client($) 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 Limited Liability Company - For Profit Yes Domestic Yes Individual Ghislaine Maxwell is the sole owner of the entity details below Ghislaine Maxwell DOB: SSN: Govt. ID: Florida D/L # 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 No No JPMC Network 08/22/2011 This is another part of an existing client relationship with Ghislaine Maxwell. Ghislaine Maxwell is the daughter of the late Robert Maxwell, a British media proprietor and former Member of Parliament. Ghislaine Maxwell was educated at Marborough College and Balliol College, Oxford. Ghislaine Maxwell is an entrepreneur/business owner. She has requested the opening of a checking account for personnnel recruitment company. 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? No Source of Wealth/Financial Information EFTA01594105 Client Category(for SOW) Source of Wealth- identify the clients source of wealth from the list of options Provide detailed and specific information. Which country(ies) is(are) the Client's primary Source of Wealth derived? Is this an Operating Company? Total Net Worth $ What was the total net worth based on? Is this client a Professional Service Provider acting as a intermediary (Gatekeeper/Financial Liaison), with assets held on behalf unidentified underlying clients unknown to the bank? For Profit Other Ghislaine Maxwell is the daughter of the late Robert Maxwell, a British media proprietor and former Member of Parliament. Ghislaine Maxwell was educated at Marborough College and Balliol College, Oxford. Ghislaine Maxwell is an entrepreneur/business owner. UNITED STATES No 30000000.00 Financial Statements No following or Income financial of one or more EFTA01594106 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? No No No aa. None of the above No 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 What is the initial/ongoing source of funding for the client's Deposit Account(s) ? The initial source of funding will be $100,000 and will be from an internal transfer from the client's savings account. The ongoing source of funding will be from the payment of recruiting services performed for clients. What is the purposed/intended use of account(s)? Please provide a detailed description of how the Deposit Account(s) will be used by the client. The client has started a personnel recruitment consulting business. Checks received from clients for recruiting services performed will be deposited into a checking account and will be used for everyday living expenses and monthly bills. Expected Activity Levels EFTA01594107 Low (1-10) Low (1-10) Low (1-10) Low (1-10) Anticipated Dollar Amount Totals per Month $10,000 TO $50,000 $10,000 TO $50,000 $10,000 TO $50,000 $10,000 TO $50,000 Additional Client Information Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.) Approval History Stage Name Banker Attestation Market Manager Approval Signoff Date 10/14/2011 1:38 PM 10/21/2011 4:42 PM Owner SID N256838 U037276 Owner Name PAUL V MORRIS THOMAS K SOUTHMAYD EFTA01594108 DF#@&T15#7@1 EFTA01594109