EFTA Document EFTA01594181

KYC Summary Ticket#: Initiated Date: 1414786507980 02/15/2014 13:24 Client Name: Ghislaine Maxwell Client Type: Individual ECI: 0106585908 Banker: JAMES N BUCKLEY (W307403) LOB: PB Nationality: UNITED STATES KYC Status: Complete KYC Type: KYC One Year Periodic Review Primary Information Ghislaine Maxwell - ECI: 0106585908, 1000 VENETIAN WAY APT 801, MIAMI BEACH, FL 331391043 Primary Information Is the Client a JPMC employee? No Front Office Restricted? Normal Prefix / Title Full Name Ghislaine Maxwell Date of Birth Primary country of domicile UNITED STATES Is the Client a US Citizen? Yes Client Addresses Postal Legal Address Title Address Confidential Address No Phone Home 1 Notes Home 1 Notes JPMC Internal Use Only Extension This is a Call Back Number No EFTA01594181 Company Name Mailing Label Salutation First Name Ghislaine Generation Middle Name Previous Name / Alias Mother's Maiden Name MEYNARD Primary state of domicile Florida Last Name Maxwell Gender Female Country of Citizenship UNITED STATES Primary country of assets UNITED STATES Suffix Marital Status Extension This is a Call Back Number No 1 EFTA01594182 Email Home Identification & Tax Info Tax Type of Tax ID Social Security Number Identification Form of Government ID NONE Why are you asking for an exception to the policy, and what actions are being taken to mitigate risk? Attached florida drivers license is poor quality. According to last KYC attached, license number is M240-294-61-965-0. Accounts for this client have all closed as they were asked to leave by rick committee, so asking for an ID from client now is not appropriate Withholding Federal Status Domestic Certified Client Coverage Client Coverage Decision Maker ECI 0106585908 Banker SID W307403 Investor SID E188557 Decision Maker Full Name GHISLAINE MAXWELL Banker Full Name JAMES N BUCKLEY Client Service Team ID 854 Client Service Team Name Cost Center Code CHBG (DE) 4 008634 Investor Full Name JASON A BELL Introduction Client Introduction Details How were you introduced to the client? Maxwell was referred by Jeffrey Epstein, a former client of the Private Bank and advisor to Leslie Wexner, also a longstanding client. They referred her to Jes Staley, who then referred Ghislaine Maxwell to our team. What additional research have you done on the client, aside from meeting them in person? JPMC Network: Maxwell was referred by Jeffrey Epstein, a former client of the Private Bank and advisor to Leslie Wexner, also a longstanding client. Jes Staley met with Ghislaine Maxwell; online research; referrals from intermediaries. James Buckley is the latest banker to have met Ghislaine Maxwell in person Has the banker or other appropriate officer of JPMorgan met the client in EFTA01594183 person? Yes PEP Is the client a current or former Senior United States or Non-USA Official / also known as a Politically Exposed Person (PEP), related to a PEP, or closely associated with a PEP? No Source of Wealth / Financial Information Which country(ies) is(are) the Clients primary Source of Wealth or Income derived? UNITED STATES Is 10% or more of the wealth derived from assets, investments or company ownership in any OFAC Sanctioned Countries? No Employment Status Unemployed Source(s) of Wealth - identify the clients source(s) of wealth from the following list of options Inheritance Inheritance JPMC Internal Use Only 2 Social Security Number 133-78-4883 EFTA01594184 Provide a description as to how and when the original wealth was created, including the primary individual from whom the weatlh came. (specifically include the name of the individual, date of birth, Tax ID if available, and relationship to the client) CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 We understand her wealth came from trusts her father Robert Maxwell left behind after he passed away on 5 November 1991. Wealth is inherited from her late father, Robert Maxwell, who died in 1991. Because of circumstances surrounding the closing of the account per risk committee's request, we cannot request any additional information from client. Ghislaine was originally referred to the PB by Jes Staley. She does not work, but volunteers for a charitable organization she founded, The TerraMar Project (www.terramarproject.org). TerraMar's mission is to create and empower a global community of ocean citizens. We promote awareness, responsibility and transparency of the high seas. The web-based nonprofit empowers the global community through citizenship, education and social engagement through The TerraMar Project. Ghislaine is the daughter of the late Robert Maxwell (DOB: 10 June 1923, DOD: 5 November 1991) - Maxwell established the Maxwell Foundation in Liechtenstein in 1970. After briefly losing control of Pergamon Press Ltd (PPL) in the early 1970s (see Controversy below), in 1974 he reacquired the company. Maxwell acquired the British Printing Corporation (BPC) in 1981, and changed its name to the British Printing and Communication Corporation (BPCC) and then to the Maxwell Communications Corporation. The company was later sold in a management buy-out, and is now known as Polestar. In July 1984 Maxwell acquired Mirror Group Newspapers from Reed International plc. MGN published the Daily Mirror, a pro-Labour Party tabloid newspaper. He also bought the American interests of the Macmillan publishing house. By the 1980s Maxwell's various companies owned the Daily Mirror, the Sunday Mirror, the Scottish Daily Record and Sunday Mail and several other newspapers, Pergamon Press, Nimbus Records, Collier books, Maxwell Directories, Prentice Hall Information Services, Macmillan (US) publishing, and the Berlitz language schools. He also owned a half-share of MTV in Europe and other European television interests, Maxwell Cable TV and Maxwell Entertainment. In 1987 Maxwell purchased part of IPC Media to create Fleetway Publications. In June 1985, Maxwell announced a takeover of Sir Clive Sinclair's ailing home computer company, Sinclair Research, through Hollis Brothers, a Pergamon Press subsidiary.[11] However the deal was aborted in August 1985.- [12] Maxwell's links with Eastern European totalitarian regimes resulted in a number of biographies (generally considered to be hagiographies[13]) of those countries' then leaders, with interviews conducted by Maxwell, for which he received much derision.[14] Maxwell was also well known as the chairman of Oxford United Football Club, saving them from bankruptcy and leading them into the top flight of English football, winning the League Cup in 1986. Maxwell bought into Derby County F.C. in 1987. He also attempted to buy Manchester United in EFTA01594185 1984, but refused owner Martin Edwards' asking price. Describe the approximate value when received, and how it compares to the net worth today. CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014. Because of circumstances surrounding the closing of the account per risk committee's request, we cannot request any additional information from client. Wealth is inherited from her late father, Robert Maxwell, who died in 1991. Because of circumstances surrounding the closing of the account per risk committee's request, we cannot request any additional information from client. Ghislaine was originally referred to the PB by Jes Staley. She does not work, but volunteers for a charitable organization she founded, The TerraMar Project (www.terramarproject.org). TerraMar's mission is to create and empower a global community of ocean citizens. We promote awareness, responsibility and transparency of the high seas. The web-based nonprofit empowers the global community through citizenship, education and social engagement through The TerraMar Project. Ghislaine is the daughter of the late Robert Maxwell (DOB: 10 June 1923, DOD: 5 November 1991) - Maxwell established the Maxwell Foundation in Liechtenstein in 1970. After briefly losing control of Pergamon Press Ltd (PPL) in the early 1970s (see Controversy below), in 1974 he reacquired the company. Maxwell acquired the British Printing Corporation (BPC) in 1981, and changed its name to the British Printing and Communication Corporation (BPCC) and then to the Maxwell Communications Corporation. The company was later sold in a management buy-out, and is now known as Polestar. In July 1984 Maxwell acquired Mirror Group Newspapers from Reed International plc. MGN published the Daily Mirror, a pro-Labour Party tabloid newspaper. He also bought the American interests of the Macmillan publishing house. By the 1980s Maxwell's various companies owned the Daily Mirror, the Sunday Mirror, the Scottish Daily Record and Sunday Mail and several other newspapers, Pergamon Press, Nimbus Records, Collier books, Maxwell Directories, Prentice Hall Information Services, Macmillan (US) publishing, and the Berlitz language schools. He also owned a half-share of MTV in Europe and other European television interests, Maxwell Cable TV and Maxwell Entertainment. In 1987 Maxwell purchased part of IPC Media to create Fleetway Publications. In June 1985, Maxwell announced a takeover of Sir Clive Sinclair's ailing home computer company, Sinclair Research, through Hollis Brothers, a Pergamon Press subsidiary.[11] However the deal was aborted in August 1985.- [12] Maxwell's links with Eastern European totalitarian regimes resulted in a number of biographies (generally considered to be hagiographies[13]) of those countries' then leaders, with interviews conducted by Maxwell, for which he received much derision.[14] Maxwell was also well known as the chairman of Oxford United Football Club, saving them from bankruptcy and leading them into the top flight of English football, winning the League Cup in 1986. Maxwell bought into Derby County F.C. in 1987. He also attempted to buy Manchester United in 1984, but refused owner Martin Edwards' asking price. EFTA01594186 Total Net Worth $10,000,000.00 What was the total net worth based on Other If Other, please describe Clients investable assets were FORMERLY held at PB, the rest of her wealth is held in her real estate and artwork (NYC Townhouse and London townhouse). CLIENT EXISTED THE BANK AND ASSETS CLOSED JUNE 8, 2014 AS RISK COMMITTEE REQUESTED. Because of circumstances surrounding the closing of the account per risk committee's request, we cannot request any additional information from client. Provide a detailed narrative of how the stated net worth/source of wealth of the client was verified. Please attach any supporting documentation to the KYC. Ghislaine was originally referred to the PB by Jes Staley. She does not work, but volunteers for a charitable organization she founded, The TerraMar Project (www.terramarproject.org). TerraMar's mission is to create and empower a global community of ocean citizens. We promote awareness, responsibility and transparency of the high seas. The web-based nonprofit empowers the global community through citizenship, education and social engagement through The TerraMar Project. Ghislaine is the daughter of the late Robert Maxwell (DOB: 10 June 1923, DOD: 5 November 1991) - Maxwell established the Maxwell Foundation in Liechtenstein in 1970. After briefly losing control of Pergamon Press Ltd (PPL) in the early 1970s (see Controversy below), in 1974 JPMC Internal Use Only 3 EFTA01594187 he reacquired the company. Maxwell acquired the British Printing Corporation (BPC) in 1981, and changed its name to the British Printing and Communication Corporation (BPCC) and then to the Maxwell Communications Corporation. The company was later sold in a management buyout, and is now known as Polestar. In July 1984 Maxwell acquired Mirror Group Newspapers from Reed International plc. MGN published the Daily Mirror, a pro-Labour Party tabloid newspaper. He also bought the American interests of the Macmillan publishing house. By the 1980s Maxwell's various companies owned the Daily Mirror, the Sunday Mirror, the Scottish Daily Record and Sunday Mail and several other newspapers, Pergamon Press, Nimbus Records, Collier books, Maxwell Directories, Prentice Hall Information Services, Macmillan (US) publishing, and the Berlitz language schools. He also owned a half-share of MTV in Europe and other European television interests, Maxwell Cable TV and Maxwell Entertainment. In 1987 Maxwell purchased part of IPC Media to create Fleetway Publications. In June 1985, Maxwell announced a takeover of Sir Clive Sinclair's ailing home computer company, Sinclair Research, through Hollis Brothers, a Pergamon Press subsidiary.[11] However the deal was aborted in August 1985.- [12] Maxwell's links with Eastern European totalitarian regimes resulted in a number of biographies (generally considered to be hagiographies[13]) of those countries' then leaders, with interviews conducted by Maxwell, for which he received much derision.[14] Maxwell was also well known as the chairman of Oxford United Football Club, saving them from bankruptcy and leading them into the top flight of English football, winning the League Cup in 1986. Maxwell bought into Derby County F.C. in 1987. Expected Account Activity Product Family Banking Investments Banking Please provide a detailed description of the purpose/intended use of the Banking account(s). CLIENT EXISTED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 Please describe any significant transactions over the last 12 months, including any that are outside of the expected account activity previously documented for the client. CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 Investments Please provide a detailed description of the purpose/intended use of the Investment account(s). Investments : This was a long-standing brokerage relationship. Continued source of funding was from investment proceeds.; We opened and funded (from cash) TAP ARFI, TAP DYS and OAP, IHD strategies - fully managed by JPM. Continued source of funding (if any) would come from investment proceeds. Please describe any significant transactions over the last 12 months, EFTA01594188 including any that are outside of the expected account activity previously documented for the client. CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 The following questions apply to all accounts for this client What is the initial source of funding for the client's account(s)? CLIENT EXITED THE BANK AND ASSETS CLOSED JUNE 8, 2014 AS RISK COMMITTEE REQUESTED. Because of circumstances surrounding the closing of the account per risk committee's request, we cannot request any additional information from client. What is the ongoing source of funding for the client's account(s)? CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014. Because of circumstances surrounding the closing of the account per risk committee's request, we cannot request any additional information from client. Wire Transaction Activity What type of wire transfer activity is expected? Wire activity is not expected Automatic Clearing House Transaction Activity What type of ACH activity is expected? ACH activity is not expected Cash Transaction Activity How many cash deposits and withdrawals does the client expect to make each month? Cash activity is not expected Before answering the following question, please review the Account History Activity Summary Report that has been attached to this ticket. Did the actual transaction activity appear reasonable, normal, and expected for the client based on what you know about the client of the business or industry in which the client engages? Yes Cash Activity: Summarize client cash activity during the period reviewed and explain the purpose / use of the funds: CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 Wire Activity: Summarize client wire activity during the period reviewed and explain the purpose / use of the funds, including any international/cross border wires: CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 Was the nature, value, and volume of actual transaction activity consistent with expected transaction activity? Yes Was any unusual or potentially suspicious transaction activity detected? JPMC Internal Use Only 4 EFTA01594189 No Additional Comments CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 Business Case Summary of Risk Attributes Reputational - 2011 media alleging Maxwell solicited young girls for then boyfriend Jeffrey Epstein. Epstein was convicted for solicitation of a prostitute and procurring a person under age 18 for prostitution. He was the subject of a previous Management Review and has been exited from the Bank. In a 12/6/13 RRC mtg, the decision was made to exit Maxwell. Even though all of Maxwell's banking accounts have been closed (only credit cards remain), the ticket needs to be completed to close the loop on the exit. 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 We are no longer comfortable with this client. CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 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. Maxwell was referred by Jeffrey Epstein, a former client of the Private Bank and advisor to Leslie Wexner, also a longstanding client. Jes Staley has met with Ghislaine Maxwell. Client known to whom (JPM employees), how well and how long Maxwell was referred by Jeffrey Epstein, a longstanding client of the Private Bank and advisor to Leslie Wexner, also a longstanding client. Jes Staley got the original referral from Jeff Epstein, and he referred Ghislaine Maxwell on to our team. Overall PB/PWM relationship size and type of accounts ALL ACCOUNTS ARE CLOSED CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 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? NOT SHARED ALL ACCOUNTS ARE CLOSED CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014 Describe any significant changes in the client's information or material events that may have occurred over the last year CLIENT EXISTED THE BANK AND ASSETS CLOSED JUNE 8, 2014 AS RISK COMMITTEE REQUESTED. Additional Parties Risk Assessment Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.) EFTA01594190 THIS CLIENT EXITED THE BANK AND ASSETS CLOSED JUNE 8, 2014 AS RISK COMMITTEE REQUESTED. KYC completed as a result on a best efforts basis, given client could not be contacted to gather additional informaton. Banker Attestation Banker Attestation As the client sponsor, I understand that I am primarily responsible for protecting the firm's reputation from inappropriate business relationships, as well as prevent 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. Yes Please state your rationale for conducting business with this client Ghislaine Maxwell was asked to leave the bank by our Risk Committee. Her assets have all left the bank and her accounts have all since closed. She is no longer a client of the Private Bank. Comments 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)? Yes Summary Risk Factors and Indicators Risk Factors: No Risk Factors Present JPMC Internal Use Only 5 EFTA01594191 Risk Indicators: No Government ID : None Risk Rating Initial Risk Rating Standard Reason for Adjusted Risk Rating Negative media - human rights issue Report Requested from GS&I Full Summary of Risk Attributes Reputational - 2011 media alleging Maxwell solicited young girls for then boyfriend Jeffrey Epstein. Epstein was convicted for solicitation of a prostitute and procurring a person under age 18 for prostitution. He was the subject of a previous Management Review and has been exited from the Bank. In a 12/6/13 RRC mtg, the decision was made to exit Maxwell. Even though all of Maxwell's banking accounts have been closed (only credit cards remain), the ticket needs to be completed to close the loop on the exit. GSI Report Current Report Type: Full Main Client Report Type: Full GSI Grid Search Type Company Information No additional research necessary. Corporate Records No additional research necessary. Other Database Searches No additional research necessary. Internal Database Search (SPEADD/FPS) Internal database search revealed prior GDDO research for Ghislaine Maxwell and the following derogatory information was reported: 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. Reference the account titled "116 East 65th St LLC" (attached document labeled 8168599138) AND account titled "Pot and Kettle" (attached document labeled 5116964118) for previous research. Court Searches No additional research necessary. Personal Particulars No additional research necessary. Publications No additional research necessary. Regulatory Sanctions No additional research necessary. OFAC/Control List Search No additional research necessary. EFTA01594192 GSI Red Dot Has this been identified as Red Dot KYC? No Negative or Inconsistent Information Yes Please respond to any issue identified in the GS&I grid that either needs further review or red dot which is not already covered in Business Case within the KYC Ghislaine Maxwell was asked to leave the bank by our Risk Committee. Her assets have all left the bank and her accounts have all since closed. She is no longer a client of the Private Bank. Comments JPMC Internal Use Only 6 No No No No No Yes No No No Further Review Required Final Risk Rating High EFTA01594193 (No Comments Available) Audit Trail Date / Time Stage 06/24/2014 10:00 Compose 08/19/2014 20:27 Market Manager Approval Owner Name JAMES BUCKLEY (W307403) 08/12/2014 17:05 Banker Attestation JAMES BUCKLEY (W307403) MARY CASEY (U043917) 08/20/2014 11:21 Regional Director Approval WILLIAM SHERIDAN (U095563) 09/24/2014 14:03 LOB CEO Approval JOHN DUFFY (U093971) JPMC Internal Use Only Team Onboarding Owner KYC PB ATTESTORS KYC PB MARKET DIRECTOR KYC PB CEO DIRECT REPORT KYC PB CEO Detail Initiated Ticket Approved Client Approved Client Approved Client Approved Client JPMC Internal Use Only 7 EFTA01594194