EFTA Document EFTA01594231

USCG Due Diligence Report - Corporation DDR Name: 116 East 65th St., LLC - DDR Status: Process Completed Banker Information Banker: Mary C Casey/JPMCHASE LE/OU: Banker SID: Banker BAC: Banker FNEN: Banker History: 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 Banker 116 East 65th St., LLC Air Ghislaine, Inc. Air Ghislaine, Inc. Darren K. Indyke PLLC Epstein, Jeffrey Epstein, Jeffrey Epstein, Jeffrey Epstein, Jeffrey Epstein, Jeffrey Epstein, Jeffrey Freedom Air International, Inc. HBRK Associates Inc. Hyperion Air, Inc. I-Correct.com LLC Jege, Inc. LYN & JOJO LLC MAX Foundation Maxwell, Ghislaine 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 Haze Trust Corporation Name/Contact Information Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Morris, Paul V Morris, Paul V EFTA01594231 Morris, Paul V Morris, Paul V Morris, Paul V Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Rieth, Mary Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Morris, Paul V 99/31167 U043917 8634--CHBG 01 Security Services Search Date 02/02/2009 02/05/2009 02/05/2009 10/17/2008 05/21/2003 12/10/2008 12/10/2008 04/16/2010 04/16/2010 03/07/2011 03/11/2010 10/17/2008 02/03/2009 01/30/2009 02/03/2009 07/31/2006 12/10/2009 03/31/2005 01/30/2009 12/01/2008 12/02/2008 11/25/2008 Only Select "New Client" if this entity will be a PCN. Full Legal Corporate Name: 116 East 65th St., LLC (No P.O. Box address. Must be a physical address.) JPMC Internal Use Only EFTA01594232 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 10065 UNITED STATES 301 East 66th St., Suite 108 New York NY 116 East 65th St., LLC 134138373 Remember to collect W-8's or other applicable tax forms for each jurisdiction. ()NY LLC Operating Agreement Introduction / Financial Information Introduction Type: Specific Information: Have you met with the Principal/Authorized Individual? If you did not meet with the Principal/Authorized Individual, please indicate why you have not met and when you will. Legal Entity: Limited Liability Corporation What is the purpose for forming the LLC? I have not met with Ms. Maxwell but know her advisor, Jeffrey Epstein. Jes Staley has met with Ms. Maxwell. Limited Liability Company The account holds Ghislaine Maxwell's NY residence and is used to pay real estate taxes and operating expenses. Princpal Beneficial Owner(s)/Shareholder(s) Identify the principal beneficial owner(s)/shareholder(s). If the entity is owned by an intermediate legal structure (e.g. LLC or Partnership), list the ultimate individual beneficial owner(s). EFTA01594233 A beneficial owner is any person on behalf of whom the account is maintained. Last Name: First Name: Maxwell Ghislaine Source of wealth of the beneficial owner(s)/shareholder(s): Source of wealth of the Partners: Other (Provide detailed and specific information) Upon opening her account, Ms. Maxwell indicated that she is a real estate professional in NY. She is also the daughter of the late Robert Maxwell. % of Ownership 100 133784883 Other DOB Form of Govt Issued ID Obtained Passport Related Client A/C Jeffrey Epstein (Please identify referral source, etc.) Citizenship UNITED STATES Is this an operating company? Entity/Client Net Worth: $ 10.00 (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. Her assets at JPM and our understanding of her balance sheet. PRIVATE HOUSEHOLDS NAIC Code: 814100 EFTA01594234 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 Operational checking account to pay real estate taxes. Other If "Other" please describe Transfer from existing account at JPM $15,000 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) 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 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. EFTA01594235 Payment of real estate operating expenses. Anticipated $ Amount Totals per month — Please provide at least an estimate Below $1MM Full DDR originally created in ICG. Last report signed off by Security Services on 1/23/08. Search Type Is Security Service Details: Further Review Banker Response: EFTA01594236 by Banker Require d? Company Information Corporate Records Other Database Searches (RDC/CDC/MIS) Internal Database Search (CSSS/FPS) State Court Searches No No No No No Federal Court Searches No Personal Particulars Publications Regulatory Sanctions No No No OFAC/Control List Search No No additional research necessary. No additional research necessary. No additional research necessary. Information confirmed; details included in the attachment. No additional research necessary. No additional research necessary. No additional research necessary. Publications revealed nothing derogatory. No records were found. No records were found. Has this been identified as a Red Dot DDR? : Expense No.: Total Costs: Signed by: Dated: 99/31167 $0.00 Aaron X Radvanyi 02/02/2009 09:03:25 AM Background Checks conducted in addition to Security Services Background Check Date (Required If Check Carried Out) 02/17/2009 Comments (Required If Check Carried Out) EFTA01594237 Ghislaine Maxwell is an existing client and a DDR was completed on her in 2003. This real estate account was created in the International DDR database in 2006, and this US DDR is to update her information on the US database. Ms. Maxwell is known to Jes Staley. Summary Summary Of Findings: Ghislaine Maxwell is an existing client and a referral from Jeffrey Epstein. This account pays her real estate taxes and other expenses related to her NY residence of the same address as the account title. Ghislaine Maxwell is a "high profile figure" for two reasons: i) she is the daughter of the late Robert Maxwell, who died under suspicious circumstances; and ii) she is a close friend of Jeffrey Epstein and his office manages her affairs. On the latter, Mr. Epstein was convicted of a felony and is currently serving a jail term. Jes Staley conferred with Steven Cutler and the decision was made to keep him as a PB client but only for banking and custody. On the former, we have no reason to believe that she had any participation in or influence over the fraudulent activities of which her late father and brothers were once EFTA01594238 accused in the UK. Anticipated Product(s) Deposits Client Hierarchy Assignments GRAY SHADED AREA CONTAINS SPN/CAS ID ASSIGNMENT INFORMATION Banker SID U043917 Banker BAC: FNEN: 8634--CHBG 01 Does the DDR have Multiple Entities? Client Hierarchy and Additional Entity Assignment: Name 116 East 65th St., LLC Linked to DM Name JEFFREY E. EPSTEIN Date of Birth Tax ID Existing CAS Id 134138373 SPN No 7704690 Contact Information for each entity named within the Client Hierarchy Table: Associated Entity Goverment issued I.D Obtained 116 East 65th St., LLC Do any of the above entities require a joint SPN? Select Yes, if multiple entities will share the same account (OMNI, CASII or Olympic) Tax ID # 134138373 0220476439 Linking to DM Id 9710670708 CAS ID 0220476439 Citizenship Does the DDR have Multiple Owners? Name Goverment issued I.D Obtained Attention State Citizenship EFTA01594239 Address Line 1 Zip Tax ID # Date of Birth Address Line 2 City Province Country Approval Information Public/High Profile Figure Yes If a Public/High Profile figure, please select one of the following: 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: Area Head: Mary C Casey/JPMCHASE 99/31167 Marcus Sheridan/JPMCHASE Catherine Keating/JPMCHASE Prominent person who is perceived to be controversial No No No EFTA01594240 Annual / Periodic Review Information Annual/Periodic Review Due in: 12 months Banker Approval Information Sponsorship affirmation - Based on my due diligence and the information provided , I approve and accept sponsorship of 116 East 65th St., LLC — as a Client from inception and throughout the client relationship. Mary C Casey 02/17/2009 10:26:27 AM Senior Manager Approval Information Based on the information provided and the approval granted by Mary C Casey, I approve the acceptance of 116 East 65th St., LLC — as a Client. Marcus Sheridan 02/24/2009 05:39:00 PM Area Head Approval Information Based on the information provided and the approval granted by Mary C Casey and Marcus Sheridan, I approve the acceptance of 116 East 65th St., LLC — as a Client Catherine Keating 02/26/2009 07:27:53 AM Quality Reviewer Information 1st Quality Review Comment: 2nd Quality Review Comment: 3rd Quality Review Comment: 4th Quality Review Comment: 5th Quality Review Comment: Admin Comments Admin Comments: By: Date: Admin Comments History : Document History Created: 01/23/2009 Last Modified: 02/26/2009 Submitted: 02/24/2009 05:39:00 PM Recorded: 02/26/2009 07:28:38 AM Audit History 9. 'Area Head Approval' performed by: Catherine Keating on: 02/26/2009 07:28:35 AM 8. Quality Review performed by: Bonnie K Perry on: 02/25/2009 01:56:41 PM 7. 'Senior Manager Approval' performed by: Marcus Sheridan on: 02/24/2009 05:39:04 PM 6. 'Banker Approval' performed by: Mary C Casey on: 02/17/2009 10:26:29 AM 5. Assign SPN/CAS ID/Tax ID performed by: Bonnie K Perry on: 02/11/2009 02:58:46 PM 4. Submitted for Banker Approval SS Type = Full performed by: Aaron X Radvanyi on: 02/02/2009 09:03:35 AM 3. Button: 'Print' performed by: Javia S Hairston on: 01/23/2009 11:39:02 AM 2. Button: 'Flag: Security Check has begun' performed by: Javia S Hairston on: 01/23/2009 11:38:58 AM 1. Submitted for Security Services Approval performed by: Maria A. Couto on: EFTA01594241 01/23/2009 11:35:26 AM Converted Tracking Document History: Bonnie K Perry on 2/25/2009 1:56:28 PM Comments : Ok to approve. By: Maria A. Couto By: Catherine Keating By: Marcus Sheridan By: Catherine Keating CN=Sharad ..lajoo/0=3PMCHASE: 250509B.doc EFTA01594242