EFTA Document EFTA01594156

Ticket# 105258608 Client Name ECI LOB Account# MAX FOUNDATION Account Title 0309713017 PB Verify & Confirm for MAX FOUNDATION Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators Comments Summary of Risk Attributes Please summarize any material changes which have occurred with the client within the past 12 months: 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) 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 You are about to approve a high risk client. Have you included sufficient information to satisfy High Risk Enhanced Due Diligence regulatory requirements (Section 312 of the USA Patriot Act)? 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 EFTA01594156 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 Primary Information Client Type Client Status Confidential Names? Yes Yes No No High risk - Client is associated with the Epstein relationship and is in the process of being exited. Client is associated with the Epstein relationship and is in the process of being exited. High High Full No Account Type Initiated Date Initiator Initiating Team 07/13/2013 07:22 AM JUSTIN D NELSON PB FRONT OFFICE Updated Risk Previous Risk Comment Security Service Details Information not confirmed for "Max Foundation" (Tax ID and Address); Details included in the attachment. Information not confirmed for "Max Foundation" (State of Domicile); Details included in the attachment. No records were found. No records were found. No records were found. No records were found. No additional research necessary. Nothing derogatory to report. No records were found. EFTA01594157 A search of OFAC revealed no matches. No No No No No No No No Yes Yes Further Review Required Yes As stated above the client is exiting the firm. Client is exiting the firm. Client is exiting the firm. Non Individual Client No Front Office Restricted? Active Indicator Normal Yes EFTA01594158 Legal Business Name MAX FOUNDATION Country of Primary Domicile UNITED STATES Primary Country of Assets Country of Organization Industry Code (NAIC) UNITED STATES UNITED STATES Grantmaking Foundations 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 ATTN GHISLAINE MAXWELL, 16 ISLAND AVE APT 7D Phone(s)/Fax(s) Type Work Notes Phone Number Tools 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 GIO Trust Advisor Decision Maker Identification Withholding Federal Status EFTA01594159 Domestic Certified Withholding SSN/TIN Certification Date SSN/TIN/EIN Introduction & Wealth Introduction Type Net Worth of client($) Additional Party Information No additional parties available at this time Introduction Non Individual Entity Type How is the charitable entity being funded? Corporation - Not for Profit Public Donations 11/08/2013 656194566 Email Entered by Date of Update Preferred Entered by BATCH Date of Update 09/23/2009 Preferred Yes City, State, Postal Code MIAMI BEACH, Florida, 331391331 Country UNITED STATES Tools Map it Entered by Date of Update BATCH Preferred 09/23/2009 Yes Corporation 10/25/2013 Other Foundation No Insider Code (Reg. 0) Primary Domicile State WebSite EFTA01594160 Organization State Secondary Industry Code (NAIC) Client Category Please Describe Florida NAIC NOT PROVIDED [ ] Not for profit Foundation Florida Client Client Type WILLIAM M SHERIDAN 143360 - USPB UHNW NYC TRI STATE EXEC CHBG (DE) 4 Paul S Barrett JEFFREY E EPSTEIN Entity Type Portfolio Manger Investor DM ECI Entity New or Existing Client Non Individual Existing Existing JPMorgan Client - Inside LOB 20,000.00 EFTA01594161 Describe the charitable entity and its Mission/program. Include who benefits from the charitable entity. Where is the charity headquartered? What geographic locations does the charity serve? Please list all geographic locations served How are the charitable funds distributed? What is the approximate annual income/contribution received by the Charity? Who is the donor base? Who makes up the entity's volunteer base? Does this charitable entity have affiliations with any NGOs, Governments, or other organizations? Describe the entity's internal controls: Describe the entity's record keeping controls: 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. 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 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? 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. EFTA01594162 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? When was the last time you met the client? What was the reason for the meeting? Describe any significant changes in the client's information or material events that may have occurred over the last year (Examples: address changes, change in authorized persons on accounts, change in account type, change in business, change in net worth, etc,). Client is exiting the firm. Client is exiting the firm. Client is exiting the firm. Client is exiting the firm. Client is exiting the firm. Client is exiting the firm. Client is exiting the firm. No Foundation is for charitable purposes Client is associated with the Epstein relationship and is in the process of being exited. International Client is associated with the Epstein relationship and is in the process of being exited. Client is associated with the Epstein relationship and is in the process of being exited. contributions Client is associated with the Epstein relationship and is in the process of being exited. Client is associated with the Epstein relationship and is in the process of being exited. No Client is associated with the Epstein relationship and is in the process of being exited. Client is associated with the Epstein relationship and is in the process of being exited. No JPMC Network 11 Dec 2009 Ghislaine Maxwell is an existing client. Not for Profit Other Client is associated with the Epstein relationship and is in the process of being exited. UNITED STATES EFTA01594163 No 20000.00 Other IRS Form 990 for 2008 listed assets as $24,509. No f. Charities EFTA01594164 Cash Activity: Summarize client cash activity during the period reviewed and explain the purpose / use of the funds: Wire Activity: Summarize client wire activity during the period reviewed and explain the purpose / use of the funds, including any international/cross border wires: Before answering the following question please review the Annual Account History Activity Summary Report that has been attached in the Summary tab. Did the actual transaction activity appear reasonable, normal, and expected for the type of business or industry in which the client engages? Was the nature, value, and volume of actual transaction activity consistent with expected transaction activity? Was any unusual or potentially suspicious transaction activity detected? 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 What is the initial/ongoing source of funding for the client's Deposit Account(s) ? Funding amount: 18,0000ther = Other Other Detail: Transfer of account from Chase retail 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. Checking account for charitable foundation Occasional charitable contributions Review the activity for the period overall and explain how the client's transaction profile agrees with or doesn't agree with expectations for the client based on the client relationship (purpose of accounts, occupation, business activity, etc.): Client is associated with the Epstein relationship and is in the process of being exited. Was expected activity for the client modified in the transaction activity section of the KYC ticket? No Additional Client Information Please include any additional information that would further explain your EFTA01594165 knowledge of the client (family tree/history, public information, websites, etc.) This is an existing account which is being transferred from Retail into PB. Comment History Stage Name Market Manager Approval Expected Activity Levels Anticipated Dollar Amount Totals per Month Low (1-10) Low (1-10) $10,000 TO $50,000 $10,000 TO $50,000 Client is exiting the firm. Client is exiting the firm. Yes Yes No At the request of sr management client is exiting the firm. Creation Date Entered By 11/20/2013 01:49 PM ALMA DEMETROPOLIS Comment Preview Please redirect to Tad Smith/Marc Sheridan and confirm whether the comments above of moving account from Retail to PB is valid if we are exiting. MM/Banker Comments CEO Approval Approval History Stage Name Banker Attestation Market Manager Approval Market Manager Approval 12/06/2013 03:47 PM 12/15/2013 07:22 AM WILLIAM M SHERIDAN JOHN R DUFFY We will be exiting this relationship. approved to facilitate exit Signoff Date 11/08/2013 08:50 AM 11/20/2013 01:49 PM EFTA01594166 12/09/2013 03:06 PM Owner SID Owner Name WILLIAM M SHERIDAN ALMA DEMETROPOLIS ALMA DEMETROPOLIS EFTA01594167 Regional Director Approval CEO Approval 12/09/2013 05:30 PM 12/15/2013 07:22 AM DFOtg,T15#7@1 U963678 VINCENT A LA PADULA U093971 JOHN R DUFFY EFTA01594168