EFTA Document EFTA01435805

BUILDINGART, S. DE R.L. account exceeded the Incoming and Outgoing amount for January 2016. Account 11'12645 was reviewed for the period January 2016 through February 2016. Account balance: $3,184.38 There were 2 Incoming Wires totaling $1,550,000 as follows: $1MM from DETERGENTES LTDA — household products (http://www.bloomberg com/profiles/companies/6989313Z:CB- detergentes-ltda + http://www.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 <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: $300K 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.com/companies/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.appliedwayfinding.com <http://www.appliedwayfinding.com›). $150K Transfer to related A/C 18192776 - JESSAMINE GROUP LTD Account is under the GUTT, DANIEL RELATIONSHIP. Per KYC #01048205, BuildingArt, S.de R.L. is a Panamanian Corporation incorporated on 12/17/2012. They are involved in Architecture and construction operations in Panama and Bahamas. This checking account was established to meet settlement of invoices from engineers / architects involved in several construction operations being developed by Mr. Daniel Haime. The Haime Gutt family is a well known and reputable family in Bogota, Colombia. Additionally, Mr. Daniel Haime sold his tubing company called Tubo Caribe to Maverick Tube in 2005 for US$ 86 million. EFTA01435805 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. Tammy McFadden: Specify alerted INCOMING/OUTGOING amount/count activities for the month of January and Feb 2016 January - INCOMING amount $1,000,000.00 OUTGOING amount $740,526.26 Tammy McFadden: Missing link For internal use only For internal use only For internal use only EFTA01435806