EFTA Document EFTA01481345

USCG Due Diligence Report - Corporation DDR Name: Freedom Air International, Inc. DDR Type: REVISED DDR Status: Process Completed Banker Information Banker: Paul V Morris/JPMCHASE LE/OU: Banker SID: Banker BAC: Banker FNEN: Banker History: 03/04/2010 11:24:53 PM - CRD / Notrix changed: Banker from Mary C Casey/- JPMCHASE to Paul V Morris/JPMCHASE. DM ID Link Information The DM for this DDR is DM Name -JEFFREY E EPSTEIN CAS ID - 9710670708. The following DDR's are associated with this Decision Maker . DDR Name 116 East 65th St., LLC Air Ghislaine, Inc. Air Ghislaine, Inc. Darren K. Indyke PLLC Epstein, Jeffrey Epstein, Jeffrey Epstein, Jeffrey Epstein, Jeffrey Epstein, Jeffrey Epstein, Jeffrey Freedom Air International, Inc. HBRK Associates Inc. Hyperion Air, Inc. I-Correct.com LLC Jege, Inc. LYN & JOJO LLC MAX Foundation Maxwell, Ghislaine Plan D, Inc. The 2007 Jeffrey E Epstein Insurance Trust #2 - November 1, 2007 The 2007 Jeffrey E Epstein Insurance Trust #3 dtd November 1, 2007 The 2007 Jeffrey E. Epstein Insurance Trust #1 Dtd November 1, 2007 The Haze Trust Corporation Name/Contact Information Banker Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Morris, Paul V EFTA01481345 Casey, Mary C Casey, Mary C Morris, Paul V Morris, Paul V Morris, Paul V Morris, Paul V Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Rieth, Mary Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Morris, Paul V Security Services Search Date 02/02/2009 02/05/2009 02/05/2009 10/17/2008 12/10/2008 05/21/2003 12/10/2008 04/16/2010 04/16/2010 03/07/2011 03/11/2010 10/17/2008 02/03/2009 01/30/2009 02/03/2009 07/31/2006 12/10/2009 03/31/2005 01/30/2009 12/01/2008 12/02/2008 11/25/2008 102/29338 N256838 8634--CHBG 01 Only Select "New Client" if this entity will be a PCN. JPMC Internal Use Only EFTA01481346 Full Legal Corporate Name: Freedom Air International, Inc. (No P.O. Box address. Must be a physical address.) Primary Corporate Address Name: Attention: Address Line 1: Address Line 2: City: State: Province: Postal/Zip Code: Country: Tax ID # : Business Phone: State of Domicile: Where is the Company Incorporated? What document did you obtain to evidence state of domicile? Articles of Incorporation, Partnership Agreement, etc 10065 UNITED STATES 134109791 Remember to collect W-8's or other applicable tax forms for each jurisdiction. ()DE Certificate of Incorporation 8/16/2010 We are updating this DDR to reflect a title change from Schmitka Air Inc. to Freedom Air International, Inc. The client has provided us with a Certificate of Amendment of Certiificate of Incoporation of Shmita Air Inc. and a copy of the W9 reflecting this change. Introduction / Financial Information Introduction Type: Specific Information: Freedom Air International, Inc. HBRK Associates 301 East 66th St., Suite 10B New York NY Related Client A/C Jeffrey Epstein introduced Ghislaine Maxwell to the firm. 8/16/2010 We are updating this DDR to reflect a title change from Schmitka Air Inc. to Freedom Air International, Inc.. The client has provided us EFTA01481347 with a Certificate of Amendment of Certificate of Incorportion of Shmitka Air Inc.and a copy of the W-9 reflecting this change. (Please identify referral source, etc.) Have you met with the Principal/Authorized Individual? Legal Entity: Corporation Corporation What is the nature of the business operations? (Describe products and services offered, how long in business, etc. If this is an operating company, indicate appx. number of locations and appx. number of employees, list a website if available) Public or Privately owned? (if public, where traded?) Locations served? Is this a cash intensive business or a business that uses cash as it's principal activity? (e.g. convenience store, restaurants, retail stores, liquor stores, cigarette distributor, vending S-corporation that holds private aircraft. Private EFTA01481348 machine operator, parking garage, any other business in which cash is its principal activity) Principal Shareholder(s): Identify the principal shareholders. If the entity is owned by an intermediate legal structure (e.g. LLC or Partnership), please list the ultimate individual shareholder(s) on whose behalf the account is maintained. Last Name: First Name: Maxwell Ghislaine % of Ownership: 100 DOB Issued ID Obtained Driver's License Is this an operating company? Entity/Client Net Worth: $ 20.00 (USD millions) Documentation/ Information obtained to confirm stated net worth of the Entity/Client: Industry Code: The Business Type is the industry in which the client derives the majority of its income. Transaction Profile/Expected Account Activity What is the purpose/intended use of this account? What is the expected source of account funding ? Approximate $ amount to fund the account To manage operational expenses related to personal aircraft. Other If "Other" please describe Transfer in from Ms. Maxwell's personal account $50,000 Please select each "Product Type" that applies. Within each product type, please check ALL transaction types that apply and provide a description of expected account activity. (document expected sources of inflows and destinations of transfers,countries, and types of payors/payees.Include where is the money coming from - example : A specific bank or firm and purpose of specific transactions, if known) Product Type - Select all that apply Transaction Types - Select all that apply and expected activity level ( L = 1-5, M = 6-12, H =>12 transactions EFTA01481349 per month) Deposit/Current Accounts (Checking, Savings, Money Market) Cash ( withdrawals/deposits) - Check deposits / Check paid - Wire Incoming & Outgoing Internal Transfers Other Please describe in detail expected account activity for this product : Investment Products (Custody, Brokerage,Agency,Margin) Operational account for maintenance of aircraft. Anticipated $ Amount Totals per month — Please provide at least an estimate Client's liquid assets at JPM plus value of her personal real estate. PRIVATE HOUSEHOLDS NAIC Code: 814100 Below $1MM Fiduciary (Investment Mgmt. / Trust) EFTA01481350 Credit type facilities (Line of Credit, Mortgage, Letter of Credit) Required Security Services Checks Security Search Type: Note for Security Services: Please list any specific search requests/instructions to Security Services here Full DDR originally created in ICG. Last report signed off by Security Services on 2/1/08. DDR title is being changed from Air Ghislaine Inc. to Shmitka Air, Inc. (2/22/2010) DDR title is being changed from Shmitka Air, Inc. to Freedom Air International, INc. (8/16/2010) 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: Attachment: Please Note: All research is subject to the availability of electronic database resources. 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) State Court Searches Yes No No No Information not confirmed; details included in the attachment. Information confirmed;details included in the attachment. No additional research necessary. Information confirmed;details included in the attachment. Reference section of the DDR titled "Red Dot (derogatory information) identified:" to view the specifics on the adverse information GS&I has identified for this account No EFTA01481351 Federal Court Searches No Personal Particulars Publications Regulatory Sanctions No No No OFAC/Control List Search No No records were found. No records were found. No additional research necessary. Publications revealed nothing derogatory. No records were found. No records were found. Has this been identified as a Red Dot DDR? : Red Dot (derogatory information) Identified: Red Dot information is any derogatory information identified by Global Security Services which warrants the attention of the banker. The presence of "Red Dot" information does not necessarily mean that an existing relationship will be exited or a potential client relationship not pursued. The banker should document any conversations that have taken place with the client/prospect, if any, with regard of the issue and whether or not this impacts his/her, or management's decision to continue with or accept the person/entity as a client. Security Service Details (Include DDR names in which this was previously reported, if any) Proceed with or maintain the client relationship Yes / No Banker Response (If "Yes", please provide your rationale for proceeding with or maintaining the client relationship. If "No", please specify steps that will be taken) The following information was previously reported to Mary Reith on 03/17/2003 under the account 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 Discussed with management reviewed Banker Response: EFTA01481352 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). The following information was previously reported to Mary Reith on 10/20/2005 under the account Forums, LLC (DDR # 11374/04): Newspaper article dated 6/23/2005 detailing Robert Maxwell misappropriated funds from the companies under his control. According to the newspaper article, "He pledged assets as security for additional loans", but instead of delivering the assets to the lender, he would simply sell the assets for cash. "For example, Berlitz language school was supposedly sold to a Japanese publishing company, but the shares had previously been pledged as security for loans from Swiss Volksbank and Lehman Brothers." Expense No.: Total Costs: Signed by: Dated: 99/31167 $0.00 Rohit Mehra 03/11/2010 01:28:14 PM Background Checks conducted in addition to Security Services Background Check Date (Required If Check Carried Out) 05/13/2009 Comments (Required If Check Carried Out) Ms. Maxwell is an existing client with a DDR on file. She was referred by Jeffrey Epstein, an existing client with a complete DDR on file. Ghislaine Maxwell is a close friend of Jeffrey Epstein and he referred her to us. She had also met with Jes Staley around this same time in 2003. She is a high profile person given her family background (Robert Maxwell, who had been accused of fraud in the UK for allegedly using pension funds for personal debts, among other issues) and the circumstances EFTA01481353 surrounding her father's death. Because she had no involvement in her father's company or affairs, we do not feel that this is an issue for PB. She also has authority jointly with Jeffrey Epstein on several accounts. Please note that Mr. Epstein does not have authority on Air Ghislaine, Inc. Jeffrey Epstein is an existing client of PB. In years past, Mr. Epstein was an active brokerage client, particularly in foreign exchange, and as of this year he is a custody-only client. Formerly, Jeffrey Epstein was a money manager to high net worth individuals, most notably Leslie Wexner. Wexner was a JPM client and then retained Epstein in the late 90s. Mr. Wexner terminated his relationship with Epstein in 02/2008. Mr. Epstein was convicted of a felony charge in 2008 and served an 18-month prison sentence. EFTA01481354 Summary Summary Of Findings: Ghislaine Maxwell is a close friend of Jeffrey Epstein and he referred her to us. She had also met with Jes Staley around this same time in 2003. She is a high profile person given her family background (Robert Maxwell, who had been accused of fraud in the UK for allegedly using pension funds for personal debts, among other issues) and the circumstances surrounding her father's death. Because she had no involvement in her father's company or affairs, we do not feel that this is an issue for PB. She also has authority jointly with Jeffrey Epstein on several accounts. Please note that Mr. Epstein does not have authority on Air Ghislaine, Inc. Jeffrey Epstein is an existing client of PB. In years past, Mr. Epstein was an active brokerage client, particularly in foreign exchange, and as of this year he is a custody-only client. Formerly, Jeffrey Epstein was a money manager to high net worth individuals, most notably Leslie Wexner. Wexner was a JPM client and then retained Epstein in the late 90s. Mr. Wexner terminated his relationship with Epstein in 02/2008. Epstein is well known to several JPM PB employees and to Jes Staley. Mr. Epstein was convicted of a felony charge in 2008 a 8/16/2010 We are updating this DDR to reflect a title change from Shmitka Air Inc. to Freedom Air International, Inc. We have received from the client a copy of the Certificate of Amendment of Certificate of Incorporation of Shmitka Air, Inc. and a copy of a W-9 reflecting this change. Anticipated Product(s) Others Client Hierarchy Assignments GRAY SHADED AREA CONTAINS SPN/CAS ID ASSIGNMENT INFORMATION Banker SID N256838 Banker BAC: FNEN: 8634--CHBG 01 Does the DDR have Multiple Entities? Client Hierarchy and Additional Entity Assignment: Name Air Ghislaine, Inc. Linked to DM Name EFTA01481355 JEFFREY E EPSTEIN Date of Birth Tax ID 134109791 SPN No 7704674 Contact Information for each entity named within the Client Hierarchy Table: Associated Entity Goverment issued I.D Obtained Air Ghislaine, Inc. Do any of the above entities require a joint SPN? Select Yes, if multiple entities will share the same account (OMNI, CASII or Olympic) Tax ID # 134109791 Existing CAS Id 0220476436 Linking to DM Id 9710670708 CAS ID 0220476436 Citizenship EFTA01481356 Does the DDR have Multiple Owners? Name Goverment issued I.D Obtained Tax ID # Date of Birth Attention Address Line 1 State Citizenship Zip Address Line 2 Province City Country Approval Information Public/High Profile Figure No High Risk Jurisdiction High Risk Business Is this a Foreign Bank? "Foreign Bank" as defined in the USA PATRIOT Act. Banker: LE/OU: Senior Manager: Paul V Morris/JPMCHASE 102/29338 Mary C Casey/JPMCHASE No No No Annual / Periodic Review Information Annual/Periodic Review Due in: 36 months Periodic Review Comments : Banker Approval Information Sponsorship affirmation - Based on my due diligence and the information provided , I approve and accept sponsorship of Freedom Air International, Inc. — as a Client from inception and throughout the client relationship. Paul V Morris 07/14/2011 02:06:15 PM Senior Manager Approval Information Based on the information provided and the approval granted by Paul V Morris, I approve the acceptance of Freedom Air International, Inc. — as a Client. Thomas K. Southmayd 07/18/2011 10:58:25 AM Quality Reviewer Information 1st Quality Review Comment: EFTA01481357 2nd Quality Review Comment: Bonnie K Perry on 6/12/2009 3:01:32 PM Comments : Ok to approve. Client is being redocumented on USCG. Previous DDR within ICG DDR Database. EFTA01481358 3rd Quality Review Comment: 4th Quality Review Comment: 5th Quality Review Comment: Admin Comments Admin Comments: By: Date: Admin Comments History : Document History Created: 01/23/2009 Last Modified: 07/18/2011 Submitted: 03/11/2010 01:28:15 PM Recorded: 07/18/2011 10:58:29 AM Audit History 18. Senior Manager Approved on Behalf of Mary C Casey because designated Senior Manager is Senior manager unavailable. performed by: Thomas K. Southmayd on: 07/18/2011 10:58:27 AM 17. 'Banker Approval' performed by: Paul V Morris on: 07/14/2011 02:06:36 PM 16. Submitted for Banker Approval SS Type = Full performed by: Rohit Mehra on: 03/11/2010 01:28:47 PM 15. Button: 'Print' performed by: Javia S Hairston on: 02/22/2010 04:09:43 PM 14. Submitted for Security Services Approval performed by: Lucy Baglivo on: 02/22/2010 02:51:48 PM 13. DDR Regression - Status changed from: Awaiting Security Services Research to Composing for the following reason: Need to make another change performed by: Lucy Baglivo on: 02/22/2010 02:51:07 PM 12. Submitted for Security Services Approval performed by: Lucy Baglivo on: 02/22/2010 02:48:27 PM 11. Button : 'Update/Revise DDR' performed by: Lucy Baglivo on: 02/22/2010 02:45:56 PM 10. Input/Update High Profile figure set to 'No' performed by: Bonnie K Perry on: 10/30/2009 03:59:35 PM 9. 'Area Head Approval' performed by: Catherine Keating on: 06/15/2009 04:18:25 PM 8. Quality Review performed by: Bonnie K Perry on: 06/12/2009 03:02:29 PM 7. 'Senior Manager Approval' performed by: Marcus Sheridan on: 05/19/2009 01:35:27 PM 6. 'Banker Approval' performed by: Mary C Casey on: 05/19/2009 11:08:34 AM 5. Assign SPN/CAS ID/Tax ID performed by: Bonnie K Perry on: 02/11/2009 03:03:39 PM 4. Submitted for Banker Approval SS Type = Full performed by: Camila X Lopez on: 02/05/2009 11:31:44 AM 3. Button: 'Flag: Security Check has begun' performed by: Ligaya X Felismino- Stesner on: 01/23/2009 01:25:38 PM 2. Button: 'Print' performed by: Ligaya X Felismino-Stesner on: 01/23/2009 01:19:41 PM 1. Submitted for Security Services Approval performed by: Maria A. Couto on: 01/23/2009 12:37:03 PM Converted Tracking Document History: Removed flag - Sonar alerts only EFTA01481359 Bonnie K Perry/JPMCHASE 10/30/2009 03:58:28 PM By: Maria A. Couto By: Thomas K. Southmayd By: Rohit Mehra By: Thomas K. Southmayd CN=Ujwala Srinath/O=JPMCHASE: CN=Ujwala Srinath/O=JPMCHASE: CN=Ujwala Srinath/O=JPMCHASE: CN=Ujwala Srinath/O=JPMCHASE: CN=Ujwala Srinath/O=JPMCHASE: CN=Ujwala Srinath/O=JPMCHASE: 630510b.doc 250609B.doc 1137404B.doc 115408B.doc 1369906B.doc 108208B.doc EFTA01481360