EFTA Document EFTA01481361

USCG Due Diligence Report - Corporation DDR Name: Air Ghislaine, Inc. — DDR Status: Process Completed Banker Information Banker: Mary C Casey/JPMCHASE LE/OU: Banker SID: Banker BAC: Banker FNEN: Banker History: 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 Banker 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 Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Casey, Mary C Morris, Paul V Morris, Paul V EFTA01481361 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 99/31167 U043917 8634--CHBG 01 Security Services Search Date 02/02/2009 02/05/2009 02/05/2009 10/17/2008 05/21/2003 12/10/2008 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 Only Select "New Client" if this entity will be a PCN. Full Legal Corporate Name: Air Ghislaine, Inc. (No P.O. Box address. Must be a physical address.) JPMC Internal Use Only EFTA01481362 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 Air Ghislaine, Inc. HBRK Associates 301 East 66th St., Suite 10B New York NY 134109791 Remember to collect W-8's or other applicable tax forms for each jurisdiction. ()DE Certificate of Incorporation Introduction / Financial Information Introduction Type: Related Client A/C Specific Information: Have you met with the Principal/Authorized Individual? Legal Entity: Corporation Jeffrey Epstein introduced Ghislaine Maxwell to the firm. (Please identify referral source, etc.) 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?) EFTA01481363 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 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 SSN WP ion that holds private aircraft. Private DOB Form of Govt Issued ID Obtained Driver's License Is this an operating company? Entity/Client Net Worth: $ 20.00 (USD millions) EFTA01481364 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 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) Fiduciary (Investment Mgmt. / Trust) 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 Security Services Information A Security Services Check is REQUIRED for New Clients and Prospects EFTA01481365 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. 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 Full DDR originally created in ICG. Last report signed off by Security Services on 2/1/08. EFTA01481366 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 No No No No No Federal Court Searches No Personal Particulars Publications Regulatory Sanctions No No No OFAC/Control List Search No No records were found. Information confirmed;details included in the attachment. No additional research necessary. Information confirmed;details included in the attachment. 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? : Expense No.: Total Costs: Signed by: Dated: 99/31167 $0.00 Camila X Lopez 02/05/2009 11:31:44 AM Banker Response: Background Checks conducted in addition to Security Services EFTA01481367 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 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 and is currently serving an 18-month prison sentence. Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB client. Staley and PB then decided that his PB relationship will be for banking and custody only. We no longer provide brokerage execution capabilities for Mr. Epstein's accounts. Bear Stearns will hold the brokerage relationship with Mr. Epstein. EFTA01481368 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 and is currently serving an 18-month prison sentence. Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB client. Staley and PB then decided that his PB relationship will be for banking and custody only. We no longer provide brokerage execution capabilities for Mr. Epstein's accounts. Bear Stearns will hold the brokerage relationship with Mr. Epstein. Anticipated Product(s) Others Client Hierarchy Assignments GRAY SHADED AREA CONTAINS SPN/CAS ID ASSIGNMENT INFORMATION Banker SID U043917 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 EFTA01481369 JEFFREY E. EPSTEIN Date of Birth Tax ID Existing CAS 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 0220476436 Linking to DM Id 9710670708 CAS ID 0220476436 Citizenship EFTA01481370 Does the DDR have Multiple Owners? Name Goverment issued I.D Obtained Attention State Citizenship Address Line 1 Zip Tax ID # Date of Birth Address Line 2 City Province 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: Mary C Casey/JPMCHASE 99/31167 Marcus Sheridan/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 Air Ghislaine, Inc. — as a Client from inception and throughout the client relationship. Mary C Casey 05/19/2009 11:08:36 AM Senior Manager Approval Information Based on the information provided and the approval granted by Mary C Casey, I approve the acceptance of Air Ghislaine, Inc. — as a Client. Marcus Sheridan 05/19/2009 01:35:24 PM Quality Reviewer Information 1st Quality Review Comment: 2nd Quality Review Comment: EFTA01481371 3rd Quality Review Comment: 4th Quality Review Comment: 5th Quality Review Comment: Admin Comments 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. EFTA01481372 Admin Comments: By: Date: Admin Comments History : Document History Created: 01/23/2009 Last Modified: 10/30/2009 Submitted: 05/19/2009 01:35:24 PM Audit History 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 Bonnie K Perry/JPMCHASE 10/30/2009 03:58:28 PM By: Maria A. Couto By: Bonnie K Perry By: Marcus Sheridan CN=Sharad ..lajoo/0=3PMCHASE: 1369906B.doc CN=Sharad ..lajoo/0=3PMCHASE: 108208B.doc CN=Sharad Jajoo/O=JPMCHASE: 250609B.doc EFTA01481373