EFTA Document EFTA01594218

Ticket# 103265268 Client Name ECI LOB TERRA MAR PROJECT, INC. PB Account# Account Title Account Type Initiated Date Initiator Initiating Team 04/26/2012 03:39 PM DEBRA WHITE PB FRONT OFFICE Verify & Confirm for TERRA MAR PROJECT, INC. Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators Reason for Adjustment Comments Summary of Risk Attributes 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) Standard High Full No Not associated with a HRJ. Derogatory information previously addressed. Updated Risk Previous Risk Comment Security Service Details Information not confirmed on Terra Mar EFTA01594218 Project Inc for tax id and address. Information confirmed; details included in the attachment. No records were found. 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 $108 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 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 GCS Red Dot Has this been identified as Red Dot KYC? Negative Information Found No No EFTA01594219 No records were found. No records were found. No records were found. A search of OFAC revealed no matches. No No No Publications revealed nothing derogatory. No No records were found. No No Yes Further Review Required Yes No No Yes EFTA01594220 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 Primary Information Client Type Client Status Confidential Names? Legal Business Name Yes Client well known to the PB and team. Opening accounts to operate not-for profit ocean preservation initiative. No issue with the relationship. Client has recently copnsolidated portfolios at JP Morgan from several 3rd party providers. N/A Non Individual Client No Front Office Restricted? Active Indicator Country of Primary Domicile UNITED STATES Primary Country of Assets Country of Organization Industry Code (NAIC) UNITED STATES UNITED STATES Environ, Conservation, Wildlife Organi [813312] 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 116 E 65TH ST EFTA01594221 City, State, Postal Code NEW YORK, New York, 100657007 Phone(s)/Fax(s) Type Work Other Notes Phone Number Tools Verify "Do Not Call" List Verify "Do Not Call" List Email(s) Type Work Notes Email Entered by DEBRA WHITE Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team GIO Trust Advisor Decision Maker Identification Date of Update Preferred 04/26/2012 Yes Entered by SYSTEM SYSTEM Date of Update 04/26/2012 04/27/2012 Preferred Yes No Country UNITED EFTA01594222 STATES Tools Map it Entered by Date of Update BATCH Preferred 04/26/2012 Yes Corporation 04/13/2012 Corporation - Certified Articles of Incorporation Environmental and wildlife awareness of marine life. No TERRA MAR PROJECT, INC. Insider Code (Reg. 0) Primary Domicile State WebSite Organization State Secondary Industry Code (NAIC) Client Category Delaware NAIC NOT PROVIDED [ ] Not for profit Normal Delaware Client Client Type PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 GHISLAINE MAXWELL New or Existing Client Entity Type Portfolio Manger Investor DM ECI Non Individual Existing EFTA01594223 Withholding Federal Status Domestic Certified Withholding SSN/TIN Certification Date Is the TIN being applied for? No Introduction & Wealth Introduction Type Net Worth of client($) Additional Entities No additional entities available at this time Additional Party Information ECI Party Type Party Name Last Completed Search Date Individual Ghislaine Maxwell 03/31/2005 KYC Status Report Type Relation Type Completed Full Signer Powers Full Percent Owned 0.0 SSN/TIN/EIN 04/26/2012 Existing 3PMorgan Client - Inside LOB 20,000,000.00 Primary Information for Ghislaine Maxwell Client Type Client Status Front Office Restricted? Confidential Names? First Name Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Individual Client Normal EFTA01594224 No Country of Primary Domicile UNITED STATES Prefix/Title Ghislaine Maxwell UNITED STATES High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Legal Notes Address City, State, Postal Code MIAMI BEACH, Florida, Phone(s)/Fax(s) Type Home Notes Phone Number Tools Verify "Do Not Call" List Email(s) Type Home Notes send eotm from investor Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team Email Entered by BATCH Date of Update 11/12/2011 Preferred Yes Entered by EFTA01594225 BATCH Date of Update Preferred 09/03/2011 Yes Country UNITED STATES Tools Map it Entered by Date of Update BATCH Preferred 04/02/2012 Yes Individuals [999940] Generation Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets Ghislaine Maxwell Female UNITED STATES Yes Single Client Client Type PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 Entity Type Decision Maker Individual EFTA01594226 Identification Withholding Federal Status Form of government issued identification obtained for the files Primary Identification Number Date Issued Introduction & Wealth Introduction Type Net Worth of client($) Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth from following list of options Executive Management Issued By Expiration Date Withholding SSN/TIN Certification Date SSN/TIN/EIN Introduction Non Individual Entity Type How is the charitable entity being funded? Describe the charitable entity and its Mission/program. Include who benefits from the charitable entity. Corporation - Not for Profit Public Donations Our mission is to increase respect and protection for animals (with an emphasis on wildlife, particularly marine mammals) and their environment through research and education. Scientific endeavors include non-invasive research, academic writing and publication, lectures and facilitation of workshops and participation and collaboration in various academic projects. Educational activities include public presentations for schools and events, providing guidance and assistance to students and teachers, writing and publication in popular magazines and newspapers, and working with the media. Where is the charity headquartered? What geographic locations does the charity serve? How are the charitable funds distributed? New York City Domestic The principal activities of the corporation will be to support organizations and projects that will make the world's oceans cleaner and safer, sponsor educational programs to schools and the public regarding the study and protection of wildlife and the environment with an emphasis on marine mammals and marine ecosystems. What is the approximate annual income/contribution received by the Charity? Who is the donor base? EFTA01594227 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 This is a new start-up not-for-profit organization. There is no annual income at this time. The initial contribution will be $5,000. The donor base will be from public donations. Ghislaine Maxwell, Chairman, of the not-for-profit organizaiton and public volunteers of Ghislanine Maxwell's choosing. No This is a new not-for-profit start-up corporation. The organization's internal controls will be conducted by the organizations's accounting firm, Marks, Paneth & Shron, LLP. The record keeping controls will be conducted by the not-for-profit organization accounting firm, Marks, Paneth & Shron, LLP - the accounting firm used by the e Chairman, Ghislaine Maxwell. Yes JPMC Network 04/26/2012 This is another part of existing client relationship with Ghislaine Maxwell. The client has requested the opening of a business checking account for new start-up not-for-profit corporation. 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 No EFTA01594228 Client Category(for SOW) Source of Wealth- identify the clients source of wealth from the following list of options Provide detailed and specific information. Not for Profit Other Ghislaine Maxwell is the daughter of the late Robert Maxwell who was a British media proprietor and former Member of Parliament. Ghislaine Maxwell was educated at Marborough College and Balliol College, Oxford. Ghislaine Maxwell is an entrepreuner/business owner. 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? 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? 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 Low (1-10) What is the initial/ongoing source of funding for the client's Deposit Account(s) ? The initial source of funding will be from internal transfer of funds from the personal account of Ghislaine Maxwell held at JPMorgan. Any ongoing source of funding will be from donations provided by the public. 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. The purpose of the checking account will be to distribute charitable funds in the form of gifts, grants and loans to schools and organizations who support the study and protections of wildlife and the EFTA01594229 enviroment with an empahasis on marine mammals and marine ecosystems of Ghislaine Maxwell (Chairman) choosing. Additional Client Information Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.) <$10,000 Expected Activity Levels Low (1-10) Low (1-10) Low (1-10) Low (1-10) Anticipated Dollar Amount Totals per Month <$10,000 <$10,000 <$10,000 <$10,000 Robert Maxwell - DOD: November 5, 1991 UNITED STATES No 20000000.00 Financial Statements No f. Charities aa. None of the above Comment History Stage Name Creation Date Entered By There are no comments entered at this time. Approval History Stage Name Banker Attestation Market Manager Approval Comment Preview Signoff Date 07/23/2012 10:09 AM 07/24/2012 01:25 PM DF#@&T15#7@1 Owner SID Owner Name PAUL V MORRIS MARY C CASEY EFTA01594230