EFTA Document EFTA01594255

USCG Due Diligence Report - Individual DDR Name: Ghislaine Maxwell — DDR Status: Process Completed Banker Information Banker: Paul V Morris/JPMCHASE LE/OU: Banker SID: Banker BAC: Banker FNEN: Banker History: 03/04/2010 11:06:54 PM - CRD / Notrix changed: Banker from Mary C Casey/- JPMCHASE to Paul V Morris/JPMCHASE. 07/28/2006 11:00:04 PM - CRD / Notrix changed: Banker from Jeffrey M Matusow/- JPMCHASE to Mary C Casey/JPMCHASE. 07/13/2006 11:00:44 PM - CRD / Notrix changed: Banker from Mary C Casey/- JPMCHASE to Jeffrey M Matusow/JPMCHASE. 07/10/2006 11:00:44 PM - CRD / Notrix changed: Banker from Robert Baynard/- JPMCHASE to Mary C Casey/JPMCHASE. 07/07/2006 11:00:21 PM - CRD / Notrix changed: Banker from Mary C Casey/- JPMCHASE to Robert Baynard/JPMCHASE. 01/19/2006 11:00:30 PM - CRD / Notrix changed: Banker from Mary Rieth/- JPMCHASE to Mary C Casey/JPMCHASE. 04/23/2005 02:17:21 AM - CRD / Notrix changed: Banker GID from 00000043917 to U043917. DM ID Link Information The DM for this DDR is DM Name -. CAS ID - 0106585908. The following DDR's are associated with this Decision Maker . DDR Name Maxwell, Ghislaine Name/Contact Information Banker Morris, Paul V Security Services Search Date 03/31/2005 102/29338 N256838 8634--CHBG 01 Last Name: First Name: Maxwell Ghislaine Middle Name/Initial: Previous Last Name(s): Title: Business Name: (To Record Individual's Ownership Or Employer) Primary Address EFTA01594255 Addresses (Legal address on account) Name: Attention: Address Line 1: Address Line 2: City: Ghislaine Maxwell Eric Gany 457 Madison Avenue 4th Floor New York JPMC Internal Use Only (Other than Primary Address) Business Address Ghislaine Maxwell EFTA01594256 State: NY Province: Postal/Zip Code: Country: Legal Entity: Industry Code: Citizenship: Date of Birth: Gender: Tax ID # : Passport/Drivers License #: Home Phone: 10022 UNITED STATES UNITED STATES Individual / Joint PRIVATE HOUSEHOLDS**8811 NAIC Code: UNITED STATES se - igit year) Female Remember to collect W-8's or other applicable tax forms for each jurisdiction. Florida driver's license he also has a USVI driver's license. Passport copy is Introduction Information Introduction Type: Specific Information: Met With Principal? If you did not meet the Principal, give an indication of why you haven't met the individual and when you will. We have had numerous meetings with Jeffrey Epstein but not yet with Ghislaine. Jes Staley has met Ghislaine. What form of goverment issued identification document did you obtain for the files? Driver's License Financial Information Occupation, Business or Employer of the Client: Net Worth of Client: Documentation/ Information obtained to confirm stated net worth of the Client: Source Of Wealth: Please Describe: EFTA01594257 Real estate $ 3 (USD millions) Assets held at JPM. Earned She has indicated that she is a real estate professional. She is also the daughter of the late Robert Maxwell. Related Client A/C Ms. Maxwell was referred to us by Jeffrey Epstein. Transaction Profile/Expected Account Activity What is the purpose/intended use of this account? Asset account to hold pound sterling / US$ checking account. She also will open a sterling liquidity account with the UK office. Please check the types of account and expected activity for this legal entity (inflows and outflows of securities and cash) - check ALL that apply: Activity Level: Account Low (1-5 transactions/month) Medium (6-12 trs/month) High (over 12 trs/month) EFTA01594258 DDA/MMIA: SDI: Investment Management: Funds: Other: Transaction Profile/Expected Account Activity The money will come from her existing checking account. 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: Reference the Due Diligence Report titled "Jeffrey Epstein" (below attached Word document labeled 210203b) for a FULL report on Jeffrey Epstein. No research was conducted on Jeffrey Epstein under this particular DDR. Reference the Due Diligence Report titled "Ghislaine Maxwell" (1185038) for a FULL report on Ghislaine Maxwell and a MEDIA report on Robert Maxwell. No research was conducted on Robert Maxwell under this particular DDR. Ghislaine Maxwell was updated for international news and company records. Please note derogatory information was found under this DDR. Due to the fact GCS is unable to locate original template for this DDR, GCS provided an attached copy of the template (118503c) Please Note: All research is subject to the availability of electronic database resources. Attachment: Full 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 EFTA01594259 No Yes No records were found. Not researched. Not researched. Reference the Due Diligence Report titled "Jeffrey Epstein" (below attached Word document labeled 210203b) for a FULL report on Jeffrey Epstein. No research was conducted on Jeffrey Epstein under this particular DDR. Reference the Due Diligence Report titled "Ghislaine Maxwell" (1185038) for a FULL report on Ghislaine Maxwell and a MEDIA report on Robert Maxwell. No research was conducted on Robert Maxwell under this particular DDR. Ghislaine Maxwell was updated for international news and company records. Please note derogatory information was found under this DDR. Due to the fact GCS is unable to locate original template for this DDR, GCS provided an attached copy of the template (118503c) Please see DDR from 2003 for responses to each of the articles. Ghislaine Maxwell is a very close friend of Jeffrey Epstein who is an existing client and who has recommended us to her. Jes Staley also has met with her and has recommended we open an account for her. In reading the Banker Response: EFTA01594260 press articles, we have no reason to believe that she had any direct influence on or participation in the situations in which her brothers were involved. She is a high profile client given her family background and media coverage surrounding her father's death. State Court Searches No Federal Court Searches No Personal Particulars Publications No No Not researched. Not researched. Not researched. Reference the attached Word document (pages 2-3) to view publications. This information was originally reported under the 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 fraud charges brought against Kevin and Ian Maxwell (sons of Robert Maxwell). Regulatory Sanctions No OFAC/Control List Search No Not researched. Reference the attached Word document (page 4) to view OFAC EFTA01594261 search results. No matches were found. Has this been identified as a Red Dot DDR? : see above Expense No.: Total Costs: 99/31167 $0.00 Signed by: Dated: Witold X Cyrek 03/31/2005 06:05:36 PM Individual Checks Date Comments Background Check (Required If Check Carried Out) 03/31/2005 (Required If Check Carried Out) Maxwell was referred by Jeffrey Epstein, a longstanding client of the Private Bank and advisor to Leslie Wexner, also a longstanding client. Jes Staley has met with Ghislaine Maxwell. EFTA01594262 03/11/2005 Maxwell is an existing client. Summary Summary Of Findings: Jeffrey Epstein, a longstanding PB client, introduced us to Ghislaine Maxwell. She is very close to Jeffrey Epstein and has authority over his personal checking account with us. She is a NY socialite and daughter of the late Robert Maxwell. We opened a checking account for her in 2003. Recently, she requested we open a brokerage account in the US to hold Sterling and Euro, and a Sterling liquidity account in the UK. Anticipated Product(s) Deposits Investment Funds 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 Maxwell, Ghislaine Linked to DM Name Date of Birth Maxwell, Ghislaine o any o 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 No EFTA01594263 Tax ID # Existing CAS Id 133784883 SPN No 5036151 Contact Information for each entity named within the Client Hierarchy Table: Associated Entity Goverment issued I.D Obtained Driver's License Tax ID # 133784883 Linking to DM Id CAS ID 0106585908 Citizenship UNITED STATES Attention Address Line 1 State Zip Address Line 2 Province City Country EFTA01594264 Citizenship Approval Information Public/High Profile Figure No High Risk Jurisdiction High Risk Business Banker: LE/OU: Senior Manager: No No Paul V Morris/JPMCHASE 102/29338 Tad C Smith/JPMCHASE Annual / Periodic Review Information Annual/Periodic Review Due in: 36 months Periodic Review Comments : This annual/periodic review is for DMID # 0106585908 - DMID Name: . The actual review is being conducted within the Ranch Lake III, Inc DDR. Temporary Waiver Information Waiver Status: Reason for Waiver: Waiver Requested By: Date of Waiver Request: Approver for Waiver: Waiver Approved On: Banker Approval Information Based on my due diligence and the information provided , I approve the acceptance of Ghislaine Maxwell — as a Client. Mary Rieth 04/11/2005 04:05:19 PM Senior Manager Approval Information Based on the information provided and the approval granted by Mary Rieth, I approve the acceptance of Ghislaine Maxwell — as a Client. Tad C Smith 04/11/2005 06:25:52 PM Admin Comments Admin Comments: By: Date: DDR Complete Security Services is still performing the client background check. Vanessa A Williams 03/14/2005 David M Tarrio 03/14/2005 EFTA01594265 Admin Comments History : Document History Created: 03/11/2005 Last Modified: 04/11/2005 Submitted: 03/31/2005 05:05:37 PM Audit History 12. Periodic Review Changed to 36 because Not a true PEP --> By: Bonnie K Perry on: 03/13/2006 10:14:33 AM. 11. Input/Update High Profile figure set to 'No' performed by: Bonnie K Perry on: 03/11/2006 11:44:38 AM 10. 'Senior Manager Approval' performed by: Tad C Smith on: 04/11/2005 06:25:56 PM 9. 'Banker Approval' performed by: Mary Rieth on: 04/11/2005 04:05:29 PM 8. Submitted for Banker Approval performed by: Witold X Cyrek on: 03/31/2005 05:05:53 PM 7. Document Save performed by: Witold X Cyrek on: 03/31/2005 05:04:01 PM 6. Document Save performed by: Witold X Cyrek on: 03/31/2005 04:23:25 PM 5. Button: 'Flag: Security Check has begun' performed by: Witold X Cyrek on: 03/17/2005 02:14:32 PM 4. Button: 'Print' performed by: Ticey Robertson on: 03/15/2005 07:56:41 AM 3. Submitted for Security Services Approval performed by: Mary Rieth on: 03/14/2005 05:46:51 PM 2. Button: 'Approve Waiver' performed by: David M Tarrio on: 03/14/2005 01:19:54 PM 1. Button :'Request Waiver' performed by: Vanessa A Williams on: 03/14/2005 12:27:06 PM Converted Tracking Document History: By: Vanessa A Williams By: Tad C Smith By: Witold X Cyrek CN=Ujwala Srinath/O=JPMCHASE: 215605b.doc CN=Ujwala Srinath/O=JPMCHASE: 210203b.doc CN=Ujwala Srinath/O=JPMCHASE: 118503B.doc CN=Ujwala Srinath/O=JPMCHASE: 118503C.doc EFTA01594266