EFTA Document EFTA01594119

USCG Due Diligence Report - Corporation DDR Name: MAX Foundation — DDR Status: Process Completed Banker Information Banker: Paul V Morris/JPMCHASE LE/OU: Banker SID: Banker BAC: Banker FNEN: Banker History: 03/04/2010 11:27:26 PM - CRD / Notrix changed: Banker from Mary C Casey/- JPMCHASE to Paul V Morris/JPMCHASE. DM ID Link Information The DM for this DDR is DM Name -JEFFREY E EPSTEIN CAS ID - 9710670708. The following DDR's are associated with this Decision Maker . DDR Name 116 East 65th St , LLC Darren K. Ind ke PLLC 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. Max oun a ion 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 Corporation Name/Contact Information Banker Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V EFTA01594119 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 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 Only Select "New Client" if this entity will be a PCN. iPMC Internal Use Only EFTA01594120 Full Legal Corporate Name: MAX Foundation (No P.O. Box address. Must be a physical address.) Primary Corporate Address Name: Attention: Address Line 1: Address Line 2: City: State: Province: Postal/Zip Code: Country: Tax ID # : Business Phone: State of Domicile: Where is the Company Incorporated? What document did you obtain to evidence state of domicile? Articles of Incorporation, Partnership Agreement, etc 10022 UNITED STATES 656194566 Remember to collect W-8's or other applicable tax forms for each jurisdiction. ()NY Cert of Inc c/o George V. Delson Associates 110 East 59th Street New York NY MAX Foundation Introduction / Financial Information Introduction Type: Other Specific Information: Have you met with the Principal/Authorized Individual? Legal Entity: Corporation - Not For Profit (charity) Describe the Charity and its Mission/Program? (type of charity: religious, social club, civic league, etc. Please include the approximate year founded and a website, if available) What forms/documents did you obtain to support the existence of the charity? (e.g. IRS Form 990 - available on Guidestar - EFTA01594121 www.guidestar.org) Primary Source of funding/donations? (include approximate yearly income) Locations served? Authorized Individuals Please list all individuals who have authority over this entity First Name: Last Name: Ghislaine Maxwell Did you conduct an onsite visit? Please indicate when a visit is planned -Title SSN 133784883 DOB 12/25/1961 Form of Govt Issued ID Obtained passportFoundation is for charitable purposes Corporation - Not For Profit (charity) Entity belongs to Ghislaine Maxwell, an existing client of J.P. Morgan (Please identify referral source, etc.) Guidestar contributions EFTA01594122 Is this an operating company? Entity/Client Net Worth: $ 0.02 (USD millions) Documentation/ Information obtained to confirm stated net worth of the Entity/Client: Industry Code: The Business Type is the industry in which the client derives the majority of its income. Transaction Profile/Expected Account Activity What is the purpose/intended use of this account? What is the expected source of account funding ? Approximate $ amount to fund the account Checking account for charitable foundation Other If "Other" please describe Transfer of account from Chase retail 18,000 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 : Investment Products (Custody, Brokerage,Agency,Margin) Occasional charitable contributions Anticipated $ Amount Totals per month — Please provide at least an estimate EFTA01594123 IRS Form 990 for 2008 listed assets as $24,509. PRIVATE HOUSEHOLDS NAIC Code: 814100 Below $100000 Fiduciary (Investment Mgmt. / Trust) 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 Full EFTA01594124 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. Search Type Is Security Service Details: Further Review by Banker Require d? Company Information Corporate Records Other Database Searches (RDC/CDC/MIS) Internal Database Search (CSSS/FPS) No No No No Information confirmed; details included in the attachment. Information confirmed; details included in the attachment. No records were found. 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. State Court Searches No Federal Court Searches No Personal Particulars Publications Regulatory Sanctions No No No OFAC/Control List Search No Information confirmed; details included in the attachment. No records were found. No records were found. No additional research necessary. Information confirmed; details included in the attachment. No records were found. No records were found. Has this been identified as a Red Dot DDR? : EFTA01594125 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 Reith on 03/17/2003 under the account Ghislaine Maxwell (DDR # 1185/03): Several newspaper articles detailing the investigation conducted by Britain'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 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 Maxwell's 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 As stated previously, the information listed pertains to that of her father and brothers and there is no indication that she was involved in their actions. Banker Response: EFTA01594126 fraud charges brought against Kevin and Ian Maxwell (sons of Robert Maxwell). The following information was previously reported to Mary Reith on 10/20/2005 under the account Forums, LLC (DDR # 11374/04): 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 th Expense No.: Total Costs: Signed by: Dated: 99/31167 $0.00 Marisol X Torres-Soler 12/10/2009 11:44:56 AM Background Checks conducted in addition to Security Services Background Check Date (Required If Check Carried Out) 12/11/2009 Comments (Required If Check Carried Out) Ghislaine Maxwell is an existing client. Summary Summary Of Findings: Anticipated Product(s) This is an existing account which is being transferred from Retail into PB. Deposits Client Hierarchy Assignments GRAY SHADED AREA CONTAINS SPN/CAS ID ASSIGNMENT INFORMATION Banker SID N256838 Banker BAC: FNEN: Does the DDR have Multiple Entities? 8634--CHBG 01 No Client Hierarchy and Additional Entity Assignment: Name Tax ID # Existing CAS Id EFTA01594127 Linking to DM Id EFTA01594128 MAX Foundation Linked to DM Name JEFFREY E EPSTEIN Date of Birth No SPN No on Information for each entity named within the Client Hierarchy Table: Associated Entity Goverment issued I.D Obtained MAX Foundation Do any of the above entities require a joint SPN? Select Yes, if multiple entities will share the same account (OMNI, CASII or Olympic) Does the DDR have Multiple Owners? No This area is used to document individuals who DO NOT require a new CAS or SPN, but have authority over the entity or entities for which this DDR was created. Individuals documented within the above client hierarchy area do not need to be repeated in this section Name Goverment issued I.D Obtained Tax ID # Date of Birth Tax ID # 656194566 9710670 708 CAS ID 0221136343 Citizenship Attention Address Line 1 State Citizenship Zip Address Line 2 Province City Country Approval Information Public/High Profile Figure No EFTA01594129 High Risk Jurisdiction High Risk Business Is this a Foreign Bank? "Foreign Bank" as defined in the USA PATRIOT Act. Banker: LE/OU: Senior Manager: Paul V Morris/JPMCHASE 102/29338 Marcus Sheridan/JPMCHASE No No No Annual / Periodic Review Information Annual/Periodic Review Due in: 36 months Periodic Review Comments : Temporary Waiver Information Waiver Status: DDR Complete EFTA01594130 Reason for Waiver: Waiver Requested By: Date of Waiver Request: Approver for Waiver: Waiver Approved On: The DDR requires additional follow-up action/update. Lucy Baglivo 09/22/2009 Elizabeth X Hogan 09/22/2009 Banker Approval Information Sponsorship affirmation - Based on my due diligence and the information provided , I approve and accept sponsorship of MAX Foundation — as a Client from inception and throughout the client relationship. Mary C Casey 12/11/2009 07:13:58 PM Senior Manager Approval Information Based on the information provided and the approval granted by Mary C Casey, I approve the acceptance of MAX Foundation — as a Client. Marcus Sheridan 12/14/2009 10:22:43 AM Admin Comments Admin Comments: By: Date: Admin Comments History : Document History Created: 09/17/2009 Last Modified: 12/14/2009 Submitted: 12/10/2009 11:44:57 AM Audit History 11. 'Senior Manager Approval' performed by: Marcus Sheridan on: 12/14/2009 10:22:47 AM 10. 'Banker Approval' performed by: Mary C Casey on: 12/11/2009 07:13:59 PM 9. Submitted for Banker Approval SS Type = Full performed by: Marisol X Torres-Soler on: 12/10/2009 11:45:01 AM 8. Button: 'Flag: Security Check has begun' performed by: Marisol X Torres- Soler on: 12/10/2009 09:39:25 AM 7. Button: 'Print' performed by: Javia S Hairston on: 12/01/2009 03:30:11 PM 6. Resubmitted for Security Services Approval - Explanation of Modification done : Legal Corporate Address updated, as requested performed by: Lucy Baglivo on: 11/30/2009 01:02:06 PM 5. Security Services - Not Signed Off for the following reason: Need to confirm the address of the legal entity. performed by: Ryan T McGowan on: 09/28/2009 01:48:52 PM 4. Button: 'Print' performed by: Javia S Hairston on: 09/23/2009 11:11:40 AM 3. Button: 'Approve Waiver' performed by: Elizabeth X Hogan on: 09/22/2009 04:09:44 PM 2. Button :'Request Waiver' performed by: Lucy Baglivo on: 09/22/2009 03:58:34 PM 1. Submitted for Security Services Approval performed by: Lucy Baglivo on: EFTA01594131 09/22/2009 03:57:58 PM Converted Tracking Document History: By: Lucy Baglivo By: Marcus Sheridan By: Marisol X Torres-Soler CN=Ujwala Srinath/O=JPMCHASE: 9147709B.doc EFTA01594132