EFTA Document EFTA01369194

BUILDINGART S. DE R.L. account exceeded the Incoming and Outgoing amount for January 2016., Account was reviewed for the period January 2016 through February 2016. Account balance: 43.184.38 There were 2 Incoming Wires totaling $1,550,000 as follows: $1MM from DETERGENTES LTDA - household products (http://www.bloomberg.comiprofiles/compantes/69893133:CB-detergentes-ltda + http://vmnv.dersa.com.co/pagina/) at JPMC and $550K from CORSONAR SA at COUTTS AND COMPANY - related entity, Daniel Haime is a Director (https://opencorporates.com/companies/pa/199278). There were 14 Outgoing transactions totaling $1,062,732.26. Activity consisted of: 13 Outgoing Wires for amounts ranging from $300K to $3K. Sampling review of wires were sent as follows: 5300K to JP MORGAN CHASE FFC: BREMOND FINANCIAL INC, $250K to BANK OF NEW YORK FFC: BUTTERFIELD BANK (BAHAMAS) LIMITED REF: SONIA GUTT HAIME (related party). $200K to JP MORGAN CHASE FFC: ALASTOR ENTERPRISES INC - related entity, Daniel Haime is Director & President (https://opencorporates.corwcompanim/pa/111591), $51.2K to FIRST MERIT BANK NA FFC: VSA PARTNERS INC - branding company (www.vsapartners.com), and $20.0K to FIRST AMERICAN BANK FFC: APPLIED WAYFINDING INFORMATION DESIGN - Information design firm (www.appliedwayfincling.com). $150K Transfer to related A/C 18192776 - JESSAMINE GROUP LTD Account is under the GUTT, DANIEL RELATIONSHIP. Per KYC #01048205, BuildingArt, S.de R.L. is a Panamanian Corporation incorporated on 12/17/2012. They are involved In Architecture and construction operations in Panama and Bahamas. This checking account was established to meet settlement of invoices from engineers / architects involved in several construction operations being developed by Mr. Daniel Haime. The Haime Gutt family is a well known and reputable family in Bogota, Colombia. Additionally, Mr. Daniel Heinle sold his tubing company called Tubo Caribe to Maverick Tube in 2005 for US$ 86 million. The client used their account to receive funds from a household products company and a related entity as well as to send funds to related parties/entities and pay business related expenses . Similar activity found in prior case reviews. Activity is in line with KYC and does not appear suspicious. No change in profile necessary. For internal use only Comment (TWO: Speedy Wendel INCOMING/OUTGOING amount/count actmom for tha month of January and tab 2016 January INCOMING amount $1.003O00.00 OUTGOING amount 5140.526.26 Comment (7142): Missend Ink CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0061326 CONFIDENTIAL SDNY_GM_00207510 EFTA01369194