EFTA Document EFTA01481389

Ticket# 104671828 Client Name ECI LOB Account# HYPERION AIR INC Account Title PB Verify & Confirm for HYPERION AIR INC Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators Comments Summary of Risk Attributes Please summarize any material changes which have occurred with the client within the past 12 months: Creation Date Risk Updated History Entered by GCS Grid Search Type Company Information Corporate Records Other Database Searches (RDC/MIS/Factiva) Internal Database Search (CSSS/FPS) This entity belongs to Jeffrey Epstein. He typically will take large cash withdrawals from the account for fuel expenses when travelling to foreign countries. No material changes at this time. High High Full Yes Account Type Initiated Date Initiator Initiating Team 03/09/2013 04:20 AM JUSTIN D NELSON PB FRONT OFFICE Updated Risk Previous Risk EFTA01481389 Comment Security Service Details No additional research necessary. No additional research necessary. No additional research necessary. Internal database search revealed prior GS&I research for Hyperion Air Inc and J Epstein and Co, and Harry Beller and nothing derogatory to report. Internal database search revealed prior GS&I research for Jeffrey Edward Epstein and the following derogatory information was reported. Several newspaper articles were found that detail the indictment of Jeffrey Epstein in Florida on felony charges of soliciting underage prostitutes. Jeffrey Epstein served 13 months in jail. Numerous articles detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating in child trafficking and molesting underage girls. Jeffrey Epstein is required to register as a sex offender. Jeffrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding solicitation for an undisclosed amount. State Court Searches Federal Court Searches Personal Particulars Publications Regulatory Sanctions OFAC/Control List Search Negative or Inconsistent Information GCS Red Dot Has this been identified as Red Dot KYC? Negative Information Found Banker Attestation Details You are about to approve a high risk client. Have you included sufficient information to satisfy High Risk Enhanced Due Diligence regulatory requirements (Section 312 of the USA Patriot Act)? As the client sponsor, I understand that I am primarily responsible for protecting the firm's reputation from inappropriate business relationships, as well as from fraud and money laundering. By approving this KYC, I am sponsoring this client as to their character and reputation and from a legal/regulatory standpoint. Yes Yes No No EFTA01481390 No additional research necessary. No additional research necessary. No additional research necessary. A search of OFAC did not reveal any matches. Further Review Required No No No No No No No Publications revealed nothing derogatory. No No records were found. No No No EFTA01481391 Please state your rationale for conducting business with this client Comments Primary Information Client Type Client Status Confidential Names? Legal Business Name Hyperion Air is the entity that owns Jeffrey's plane. Issues on him are well documented on his own KYC. Non Individual Client No Front Office Restricted? Active Indicator HYPERION AIR INC Country of Primary Domicile UNITED STATES Primary Country of Assets Country of Organization Industry Code (NAIC) UNITED STATES UNITED STATES Personal Investment Companies [525997] Client Legal Entity Type Date of Incorporation/Situs (Date of Trust) Documentary Evidence What is the nature/purpose of this entity? High Risk Jurisdiction Address(es) Type Legal Notes Address 6100 RED HOOK QUARTER B3 Phone(s)/Fax(s) Type Other Notes Phone Number 2123270131 Tools Verify "Do Not Call" List Email(s) EFTA01481392 Type Other Notes Email Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team GIO Trust Advisor Decision Maker Identification Withholding Federal Status Domestic Certified Withholding SSN/TIN Certification Date SSN/TIN/EIN Introduction & Wealth Introduction Type Net Worth of client($) 04/18/2012 133621632 Entered by MARLON A LEWIS 04/18/2012 Date of Update Preferred Yes Entered by SYSTEM Date of Update 04/18/2012 Preferred Yes City, State, Postal Code ST. THOMAS, 00802 Country VIRGIN ISLANDS, U.S. Tools Map it Entered by Date of Update BATCH EFTA01481393 Preferred 07/24/2012 Yes Corporation 07/18/1991 Corporation - Certified Articles of Incorporation Maintenance and upkeep of the client's personal airplane Yes Is the entity a Personal Holding Company (PHC) or Personal Investment Company (PIC) located in an offshore jurisdiction? No Insider Code (Reg. 0) Primary Domicile State WebSite Organization State Secondary Industry Code (NAIC) Client Category Delaware NAIC NOT PROVIDED [ ] Profit Normal Yes Delaware Client Client Type JUSTIN D NELSON 002753 - GREENWICH CHBG (DE) 4 Paul S Barrett JEFFREY E EPSTEIN New or Existing Client Entity Type Portfolio Manger Investor DM ECI 9710670708 Non Individual Existing Entity Existing JPMorgan Client - Inside LOB 300,000,000.00 EFTA01481394 Additional Party Information ECI Party Type Party Name Last Completed Search Date 9710670708 Individual Jeffrey E Epstein 05/29/2012 KYC Status Report Type Relation Type Completed Full Signer Powers Full Percent Owned 0.0 Primary Information for Jeffrey E Epstein Client Type Client Status Front Office Restricted? Confidential Names? First Name Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Individual Client Normal No Country of Primary Domicile UNITED STATES Prefix/Title Jeffrey Epstein UNITED STATES High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Legal Notes Address EFTA01481395 6100 RED HOOK QTRS STE B3„ Phone(s)/Fax(s) Type Home Notes Phone Number Tools Verify "Do Not Call" List Email(s) Type Notes Email address not available Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team Identification Withholding Federal Status Form of government issued identification obtained for the files Date Issued Drivers License Primary Identification Number 01/15/2010 Introduction & Wealth Introduction Type Net Worth of client($) Issued By Expiration Date VIRGIN ISLANDS, U.S. 01/20/2015 Withholding SSN/TIN Certification Date SSN/TIN/EIN Email Entered by Date of Update Preferred Entered by BATCH Date of Update Preferred 02/22/2013 Yes City, State, Postal Code EFTA01481396 ST THOMAS„ 00802 Country VIRGIN ISLANDS, U.S. Tools Map it Entered by Date of Update BATCH Preferred 08/03/2012 Yes Individuals [999940] Personal Investment Companies [525997] Generation Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets Jeffrey E Epstein Male 01/20/1953 UNITED STATES Yes Single Client Client Type PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 Entity Type Decision Maker Individual EFTA01481397 Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth from following list of options ECI Party Type Party Name Last Completed Search Date 0241469053 Individual HARRY BELLER Primary Information for HARRY BELLER Client Type Client Status Front Office Restricted? Confidential Names? Country of Primary Domicile Prefix/Title First Name Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation HARRY BELLER UNITED STATES HBRK Associates Financial Advisor Individual Prospect Normal No Other KYC Status Report Type Relation Type Full Signer Powers Full Percent Owned 0.0 Generation Active Indicator Marital Status Insider Code (Reg. 0) Full Name Gender EFTA01481398 Date of Birth Primary Country of Assets High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) Type Work Notes Address 301 E 66TH ST APT 10B, Phone(s)/Fax(s) Type Work Notes Phone Number Tools 'prm Call" List Email(s) Type Notes Email address not available Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team Identification Withholding Federal Status Form of government issued identification obtained for the files Introduction & Wealth Domestic Certified None Withholding SSN/TIN Certification Date SSN/TIN/EIN 04/13/2012 Email Entered by Date of Update Preferred Entered by SYSTEM Date of Update Preferred EFTA01481399 04/13/2012 Yes City, State, Postal Code NEW YORK, New York, 100656298 Country UNITED STATES Tools Map it Entered by Date of Update DEBRA WHITE Preferred 04/13/2012 Yes HARRY BELLER Male M IIIM99401 Prospect Client Type PAUL V MORRIS 008634 - CHBG Entity Type Individual EFTA01481400 Introduction Type Net Worth of client($) Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth from following list of options ECI Party Type Party Name Last Completed Search Date 9710670708 Individual Jeffrey E Epstein 05/29/2012 Executive Management KYC Status Report Type Relation Type Completed Full Owner Powers Percent Owned 100.0 Primary Information for Jeffrey E Epstein Client Type Client Status Front Office Restricted? Confidential Names? First Name Middle Name Last Name Suffix PreviousName/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Individual Client Normal No Country of Primary Domicile UNITED STATES Prefix/Title Jeffrey Epstein UNITED STATES High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Address(es) EFTA01481401 Type Legal Notes Address 6100 RED HOOK QTRS STE B3„ Phone(s)/Fax(s) Type Home Notes Phone Number Tools Verify "Do Not Call" List Email(s) Type Notes Email address not available Cost Center & Hierarchy Client Status Client Sponsor Cost Center Client Service Team Identification Withholding Federal Status Form of government issued identification obtained for the files Date Issued Drivers License Primary Identification Number 0000025874 01/15/2010 Issued By Expiration Date VIRGIN ISLANDS, U.S. 01/20/2015 Withholding SSN/TIN Certification Date SSN TIN EIN Email Entered by Date of Update Preferred Entered by BATCH Date of Update Preferred 02/22/2013 Yes City, State, EFTA01481402 Postal Code ST THOMAS, 00802 Country VIRGIN ISLANDS, U.S. Tools Map it Entered by Date of Update BATCH Preferred 08/03/2012 Yes Individuals [999940] Personal Investment Companies [525997] Generation Active Indicator Marital Status Primary Domicile State Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets Jeffrey E Epstein Male 01/20/1953 UNITED STATES Yes Single Client Client Type PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 Entity Type Decision Maker Individual EFTA01481403 Introduction & Wealth Introduction Type Net Worth of client($) Source Of Wealth / Financial Information Details Source Of Wealth -Identify the Clients Source of Wealth from following list of options Other Introduction Non Individual Entity Type For Profit? Locations Served? Public or Private Are beneficial owners/principal shareholders associated with this business? Who owns this entity? Please Provide ownership details Corporation - For Profit Yes Domestic Private Yes Individual Jeffrey Epstein is the sole owner of the entity Jeffrey Epstein DOB: 01 20 1953 SSN: Citizen: Harry Beller is an authorized signer along with Jeff Epstein on the account - Harry Beller DOB: 05/09/1956 SSN: 081-52-0727 Citizen: US Ownership is not equal to 100%? Are there any authorized signers or any other individuals with authority over the entity? What independent background check, in addition to the Global Corporate Security ("GCS") background check, has been carried out? Check all that apply and provide the date in which the background check was conducted. (at least 1 must be selected) JPMC Network Date JPMC Network Comments This entity is 100% owned by Jeffrey Epstein. 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. EFTA01481404 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. Politically Exposed Person Are any of the beneficial owners/authorized signers or other individuals with authority over this entity a current or former Senior United States or Non-USA Political Official / also known as a Politically Exposed Person (PEP) or related to one? Source of Wealth/Financial Information Client Category(for SOW) Source of Wealth- identify the clients source of wealth from the following list of options No No Yes JPMC Network 03/12/2013 For Profit Other EFTA01481405 Provide detailed and specific information. Jeffrey Epstein is a private investor. Jeff Epstein was a money manager - made his wealth managing the money of wealthy individuals. Epstein began his financial career in 1976 as an options trader at Bear Stearns. He specialized in mathematical models such as the Black-Scholes option-pricing model and later worked in the special products division, advising high net worth clients on tax strategies. In 1980, Epstein became a partner at Bear Stearns. In 1982, Epstein founded his own financial management firm, J. Epstein & 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 women's-clothing 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. In 2003, Epstein publicly bidded for New York Magazine, along with advertising executive, Donny Deutsch, investor Nelson Peltz, publishing mogul and owner of The Daily News, Mortimer Zuckerman and film producer Harvey Weinstein. They were ultimately out bid by longtime wall street investor Bruce Wasserstein for $55 million. In 2004, Epstein and Mortimer Zuckerman, committed to finance up to $25 million to back Radar, a celebrity and pop culture magazine and Maer Roshan, its editor in chief and founder. Epstein and Zuckerman were equal partners in the venture, and Mr. Roshan retained a small ownership stake. Which country(ies) is(are) the Client's primary Source of Wealth or Income derived? Is this an Operating Company? Total Net Worth $ What was the total net worth based on? Is this client a Professional Service Provider acting as a financial intermediary (Gatekeeper/Financial Liaison), with assets held on behalf of one or more unidentified underlying clients unknown to the bank? Is this entity a Private Equity Fund (Venture Capital Fund or Leveraged Buyout)? Is this a Hedge Fund? (Pooled investment vehicles (often partnerships) that primarily invest financial capital of third party investors in enterprises that are too risky for the standard capital markets or bank loans.) Is this a Cash Intensive business? (Cash-intensive businesses/entities exist in various industry sectors and include, but are not limited to convenience stores, grocery stores, restaurants, bars, retail stores, liquor stores, cigarette distributors, privately owned ATMs, vending machine operators and parking garage operators.) Is this entity any of the following business types? Is the Entity a Personal Holding Company (PHC) or Personal Investment Company (PIC) located in an offshore jurisdiction? EFTA01481406 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. Provide client history/detail, including when the relationship was established, how it came to be in PB/PWM, client's association with other JPM LOBS, etc. Client known to whom (JPMorgan employees), how well, and how long: Overall PB/PWM relationship size and type of accounts: Is this a shared client, what other LOB has a relationship with the client? Provide relationship manager name (if known), client of other LOB since (date), and relationship size? When was the last time you met the client? What was the reason for the meeting? 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,). Cash Activity: Summarize client cash activity during the period reviewed and explain the purpose / use of the funds: Wire Activity: Summarize client wire activity during the period reviewed and explain the purpose / use of the funds, including any international/cross border wires: 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? Was the nature, value, and volume of actual transaction activity consistent with expected transaction activity? Was any unusual or potentially suspicious transaction activity detected? Additional Comments Long term client of the PB, well known to senior management and relationship monitored closely with regular reviews. No material events or developments over past twelve months. Jeffrey Epstein has been a client of the PB for over 10 years. Jeffrey's felony offense is well documented and he completed his sentence and probation two yers ago. No material developmentsor issues with client relationship over past twelve months. Integrated team, sr. management. Well developed dialogue with client. Jeffrey maintains a brokerage relationship across entities >$100 million and also maintain checking accounts for personal and business purposes. No, as of now Jeffrey works with the Private Bank. Met with him a month ago and seeing him this week. He is a US citizen but is now officially a Virgin Islands resident. EFTA01481407 UNITED STATES No 300000000.00 Financial Statements No No No No aa. None of the above No Nothing unusual -- income comes from fees he collects from clients Nothing unusual. Yes Yes No N/A EFTA01481408 Expected Activity Deposit Account(s) Transaction Types Cash Deposits Cash Withdrawals Check Deposits Checks Paid Incoming Wires (Domestic) Outgoing Wires (Domestic) Incoming Wires (International) Outgoing Wires (International) ACH Deposits ACH Payments Internal Transfer (Debits/Credits) Asset Purchases/Sales Low (1-10) What is the initial/ongoing source of funding for the client's Deposit Account(s) ? Ongoing funding comes from Mr. Epstein's personal accounts. The money in that account comes from his fees for managings clients personal funds. What is the purpose/intended use of account(s)? Please provide a detailed description of how the Deposit Account(s) will be used by the client. Managing payments for operational expenses of personal aircraft (operational and maintenance). Please note that it is not unusual for the client to withdraw $20K to $40K in cash to pay for fuel expenses when he travels to foreign countries. Review the activity for the period overall and explain how the client's transaction profile agrees with or doesn't agree with expectations for the client based on the client relationship (purpose of accounts, occupation, business activity, etc.): There was no material change to this account. Was expected activity for the client modified in the transaction activity section of the KYC ticket? No Additional Client Information Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.) This entity is 100% owned by Jeffrey Epstein. 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 has EFTA01481409 served his 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. Comment History Stage Name CEO Approval $50,001 TO $100,000 Expected Activity Levels Low (1-10) Low (1-10) Anticipated Dollar Amount Totals per Month $10,000 TO $50,000 $10,000 TO $50,000 Creation Date Entered By 06/10/2013 10:02 AM BONNIE K PERRY Comment Preview Duffy, as part of continued due diligence, met with Jeffrey Epstein on April 24, 2013 at his residence. The purpose of the meeting was to discuss his current business activities and his related account activity with us. Mr. Epstein is a felon. His current work involves advising clients of substantial wealth on broad issues or specific goals/transactions. As an example he was recently involved with advising Leon Black of Apollo during the purchase and financing of a prized work of art at auction ($140MM). Mr. Epstein routinely advises clients and prospects of the private bank. Mr. Epstein agreed to another meeting to further discuss his business. His demeanor was transparent and open. Subsequent to this meeting Donna Dellosso inquired regarding our account activity with Mr. Epstein. She spoke with Phil Dilorio, and will speak EFTA01481410 with Mary Erdoes. We will discuss Mr. Epstein and Risk Committee meeting in the near future. EFTA01481411 Approval History Stage Name Banker Attestation Market Manager Approval Regional Director Approval CEO Approval Signoff Date 06/03/2013 10:04 AM 06/03/2013 06:26 PM 06/06/2013 04:40 PM 06/10/2013 10:02 AM DF#@&T15#7@1 Owner SID U008568 U117517 U095563 U234588 Owner Name JUSTIN D NELSON TOWNSEND C SMITH WILLIAM M SHERIDAN BONNIE K PERRY EFTA01481412