EFTA Document EFTA01480690

What is the clients current position? (Include any former positions, if significant to source of wealth) Jeffrey Epstein (SSN: 090.44.3348 Dail: 01120/1953 US Citizen) is an existing client of PB. He is an active brokerage client across asset classes cunently covered by the Firm'sCIOdesk Jeffrey Epstein has been an investment advisor for numerous high net worth clients and abso a personal invested. Jeffrey is very .iccnssiblo and well known to the team. Wo have advised him on an estments as well as estate planning opportunities. Jeffrey has continues to be well connected across business channels. Epstein began his financial career in 1976 as an options trader at Bear Steams. He specialized in mathematical models such as the Black-Scholes oplenpncing model and later worked in the special products division, advising high not worth dents on tax strategies. In 1980. Epstein became a 'Danner at Bear Steams. In 1982. Epstein founded ha own financial management firm. J. Epstein 8 Co.. managing the assets of clients with more than a billion in net worth. In 1987. Leslie Wexner. founder and chairman of the Columbus, Ohio-based Limited chain of womeifselothing stores became a well-known client. In 1996. Epstein changed the name of his firm to The Financial Trust Company and based it in the US Virgin Islands. Epstein is well known to several JPM PB employees and senior management ado:ling Jes Staley. Also, Mr. Epstein was convicted of a felony charge in 2008. Jos Staley conferred with Stephen Culler and the decision was made to keep Mr. Epstein as a PB client. Mr. Epstein completed his sentence and probation ii 2010. The relationship has boon reviewed with senior management and corriphinotulegal on a few occasions over the post year as news stores of Jeffrey's past are picked up. No new claims or stories have surfaced recently. List the number of years in current position. (Include any former positions, If significant to source of wealth) 20 Approximate yearly income/salaryltionusIdistribution and other compensation history (accumulated earned Income) 5000000 Which country(Ies) 1st a reithe Client's primary Source of Wealth or Income derived? UNITED STATES Total Net Worth $ 500000000.00 What was the total net worth based on? Fnancial Statements Business Case Please specify why you are comfortable with this client given the Identified risk factor(s). Your answer is your "business case" and should detail all mitigating factors. Jeffrey Epstein was asked to exit the firm in August of 2013. The accounts are in the process of moving to another bank and should be closed out by yearend. Provide client historyidetail, including when the relationship was established, how it came to be in PB/PWM. clients association with other JPM LOBS, etc. Jeffrey established his relationship with the bank over 10 years ago. Client known to whom (JPMorgan employees), how well, and how long: Known to Mary Erdoes, John Duffy, and others in senior management. Overall PBMWM relationship size and type of accounts: Brokerage and deposit accounts. The ielationshp was around $200MM but is much reduced as its in the process of leaving the firm. Is this a shared client, what other LOB has a relationship with the client? Provide relationship manager name (if known), o tient of other LOB since (date), and relationship size? No When was the last time you met the client? What was the reason for the meeting? June 2013 Describe any significant changes in the client's information or material events that may have occurred over the last year (Examples: address changes, change In authorized persons on accounts, change in account type, change in business, change in net worth. etc.). Jeffrey Epstein was asked to exit the firm in August of 2013. The accounts are in the process of moving to another bank and should be closed out by yearend. Cash Activity: Summarize client cash activity during the period reviewed and explain the purpose f use of the funds: Cash activity is declining as the accounts are leaving for Deutsche Bank. Wire Activity: Summarize client wire activity during the period reviewed and explain the purpose I use of the funds, Including any International/cross border wires: Wire activity is declining as the accounts aro leaving for Deutsche Bank. Before answering the following question please review the Annual Account History Activity Summary Report that has been attached in the Summary tab. Did the actual transaction activity appear reasonable, normal, and expected for the type of business or industry In which the client engages? Yes Was the nature, value, and volume of actual tr a n saction activity consistent with expected transaction activity? Yes Was any unusual or potentially suspicious transaction activity detected? No Additional Comments N/A Expected Activity Deposit Accountjs) Transaction Types Expected Activity Levels Anticipated Dollar Amount Totals per Month Cash Deposits Low (1.10) <S10,000 Cash VVehdrevrals Low (1.10) <$10000 Check Deposits Low (1-10) <510,000 Checks Paid Low 0401 <510,000 Incoming Wires (Domestic) Confidential Treatment Requested by JPMorgan Chase CONFIDENTIAL JPM-SDNY-00002904 SDNY_GM_00272102 EFTA01480690