EFTA Document EFTA01594370

Ticket# 104483515 Client Name ECI LOB GHISLAINE MAXWELL 0106585908 PB Account# Account Title Account Type Initiated Date Initiator Initiating Team 01/30/2013 12:44 PM MARIA A COUTO PB FRONT OFFICE Verify & Confirm for Ghislaine Maxwell Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators 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) 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 As the client sponsor, I understand that I am primarily responsible for protecting the firm's reputation from EFTA01594370 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 Comments Primary Information Client Type Client Status Front Office Restricted? Confidential Names? First Name Middle Name Last Name Suffix Yes No No Standard Standard Full Yes Updated Risk Previous Risk Comment Security Service Details No additional research necessary.. No additional research necessary. No records found. Internal database search revealed prior GS&I research for Ghislaine Maxwell and Robert Maxwell and nothing derogatory information was reported. No additional research necessary. No additional research necessary. No additional research necessary. Information confirmed; details included in the attachment. No records found. A search of OFAC did not reveal any matches. No No No No No No No EFTA01594371 Further Review Required No No No No Completed 3-year KYC update for existing client of Private Bank. Individual Client Generation Normal No Country of Primary Domicile UNITED STATES Prefix/Title Ghislaine Maxwell Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets Single Florida Ghislaine Maxwell Female 12/25/1961 UNITED STATES EFTA01594372 PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation UNITED STATES N/A Volunteer 2 High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Legal Legal Legal Legal Notes Address 1000 VENETIAN WAY APT 801 1000 VENETIAN WAY APT 801 1000 VENETIAN WAY APT 801 1000 VENETIAN WAY APT 801 Phone(s)/Fax(s) Type Home Work Cell Other Work Fax Notes Phone Number 2128799366 2127501176 9175203106 EFTA01594373 3055881998 2125356833 2128798204 Tools Verify "Do Not Call" List Verify "Do Not Call" List Verify "Do Not Call" List Verify "Do Not Call" List Verify "Do Not Call" List Verify "Do Not Call" List Email(s) Type Home Other Notes send eotm from investor Email rkahn@hbrkassociat es.com Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team GIO Trust Advisor Identification Withholding Federal Status Form of government issued identification obtained for the files Primary Identification Number Date Issued Domestic Certified None Withholding SSN/TIN Certification Date SSN/TIN/EIN 03/05/2003 SP BATCH ELIZABETH HOGAN EFTA01594374 Date of Update Preferred 11/12/2011 Yes 11/15/2010 No Entered by BATCH BATCH TECS DATA SYSTEM SYSTEM SYSTEM Date of Update 02/15/2013 02/07/2012 06/04/2011 07/22/2011 09/02/2011 02/07/2012 Preferred Yes No No No No No City, State, Postal Code MIAMI, Florida, 331391043 MIAMI, Florida, 331391043 MIAMI, Florida, 331391043 MIAMI, Florida, 331391043 UNITED STATES Map it BATCH 06/25/2012 No UNITED STATES Map it BATCH EFTA01594375 06/25/2012 No UNITED STATES Map it BATCH 06/25/2012 No Country UNITED STATES Tools Map it Entered by Date of Update BATCH Preferred 06/25/2012 Yes No Individuals [999940] NAIC NOT PROVIDED [ ] Client Client Type KIRSTEN A SICHLER 008634 - CHBG CHBG (DE) 4 New or Existing Client Entity Type Portfolio Manager Investor Individual Existing Decision Maker 839487 Issued By Expiration Date EFTA01594376 Introduction and Wealth Introduction Type Net Worth of client($) Additional Party Information No additional parties available at this time Introduction Form of government issued identification obtained for the files ? Why asking for exception to Policy? What actions are being taken to mitigate risk? Has an employee of JP Morgan Wealth Management met the client in person? 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 None Photo ID has been requested Long-standing client of the PB - photo ID will be added as soon as received Yes JPMC Network Existing JPMorgan Client - Inside LOB 30,000,000.00 02/05/2013 Ghislaine was originally referred to the PB by Jes Staley. She is the daughter of the late Robert Maxwell (10 June 1923 — 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. EFTA01594377 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. Politically Exposed Person Is the client a current or former Senior United States or NonUSA Official / also known as a Politically Exposed Person (PEP), related to a PEP, or closely associated with a PEP? Source of Wealth/Financial Information Source of Wealth- identify the clients source of wealth from the following list of options Which country(ies) is(are) the Clients primary Source of Wealth or Income derived? Other UNITED STATES No EFTA01594378 Provide detailed and specific information. 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. Client Net Worth $ Documentation/Information obtained to confirm stated net worth of Client: If Other,please describe 30000000.00 EFTA01594379 Other Clients investable assets are held at PB, the rest of her wealth is held in her real estate and artwork (NYC Townhouse and London townhouse). 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) ? This is a long-standing existing deposit relationship. Continued source of funding is from investment proceeds. 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. For living expenses (utility bills, home maintenance, etc.) Client Directed Asset / Brokerage 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 Expected Activity Levels Low (1-10) Low (1-10) Low (1-10) Anticipated Dollar Amount Totals per Month <$10,000 <$10,000 <$10,000 Expected Activity Levels Anticipated Dollar Amount Totals per Month EFTA01594380 EFTA01594381 ACH Payments Internal Transfer (Debits/Credits) Asset Purchases/Sales Low (1-10) $10,000 TO $50,000 What is the initial/ongoing source of funding for the client's Client Directed Asset / Brokerage Account(s) ? This is a long-standing existing brokerage relationship. Continued source of funding is from investment proceeds. What is the purpose/intended use of account(s)? Please provide a detailed description of how the Client Directed Asset / Brokerage Account(s) will be used by the client. To preserve and grow wealth Managed Fiduciary/Trust 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) <$10,000 What is the initial/ongoing source of funding for the client's Managed Fiduciary/Trust Account(s) ? We recently opened and funded (from cash) TAP ARFI, TAP DYS and OAP, IHD strategies - fully managed by 3PM. Continued source of funding (if any) would come from investment proceeds. What is the purpose/intended use of account(s)? Please provide a detailed description of how the Managed Fiduciary/Trust Account(s) will be used by the client. To preserve and grow wealth Additional Client Information Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.) As requested, completing 3-year update on this long-standing PB client. Comment History Stage Name Expected Activity Levels Anticipated Dollar Amount Totals per Month Creation Date Entered By There are no comments entered at this time. EFTA01594382 Approval History Stage Name Banker Attestation Market Manager Approval Comment Preview Signoff Date 03/15/2013 11:14 AM 03/15/2013 11:16 AM DF#@&T15#7@1 Owner SID I095550 U037276 Owner Name KIRSTEN A SICHLER THOMAS K SOUTHMAYD EFTA01594383