EXHIBIT 112¶
| Too’ | 104537517 | Accidirm | ||
|---|---|---|---|---|
| JEFFREY E | ACLCAIN Len | |||
| 9710670708 | A-cost T,riv | |||
| Waco] Date | 0209/2013 10 43 | |||
| Worm | JUSTIN D NELSON | |||
| Intorno Team | PB FRONT OFFICE |
Verify & Confirm for Jeffrey Epstein¶
| Final Risk Rating | High |
|---|---|
| Initial Risk Rating | Standard |
| GCS Report Requested | Full |
| Reason for Adjustne M | Convicted Felon |
| Summary of Risk Attributes | Per bank policy. felons are considered high nail end require additional approval. |
Risk Updated History¶
| Creation Date | Entered by | Updated Risk | Previous Risk | Comment |
|---|---|---|---|---|
| --------------- | ------------ | -------------- | --------------- | --------- |
GCS Grid¶
| -1-A512.WitlEto- | iy.:… | |
|---|---|---|
| Security Service | etalls • Further ReviewRequired | |
| Concern Information | No adociona: research recce sry. | No |
| Co•porate Records | NO addeortal research necessary. | No |
| No additional research necessary. | No | |
| Internal Database Search (CSSSFPS) | Internal database search revealed prior | |
| Stare Coca Searches | No additional research necessary. | No |
| Federal Court Searches | No additional research necessary. | No |
| Personal Particulars | No additional research necessary. | No |
| Publications | No additional research necessary. | No |
| Negutatoty Sanctions | No additional research necessary. | No |
| OFACiControl List Search | No additional research necessary. | No |
| Negative or Inconsistent Information | Yes |
GCS Red Dot¶
| Has this been identified as Red Dot KYC? | Yes |
|---|---|
| Red Dot (Derogatory Information ) Identified | |
| Security Service Details | |
| (Include KYC names in which this was previously reported, if any.) |
Red Dot Information¶
| Negative Information Found | Yes |
|---|---|
| ---------------------------- | ----- |
| Banker Attestation Details | |
|---|---|
| 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 |
| Please state your rationale for conducting business with this client | Jeffrey Epstein has been an active trading client and keeps most of his liquidity with us. Total assets over $100MM. Both Mary Erdoes and John Duffy are aware of the relationship. |
| Please respond to any issue(s) identified in the GS&I grid that either needs further review, or red dot which is not already covered in a Business Case within this KYC | Senior management is aware of the relationship with Jeffrey. |
| Comments |
| Primary Information | |||
|---|---|---|---|
| Client Type | Individual | Generation | |
| Client Status | Client | Active Indicator | Yes |
| Front Office Restricted? | Normal | Marital Status | Single |
| Confidential Names? | No | ||
| Country of Primary Domicile | UNITED STATES | Primary Domicile State | New York |
| Prefix/Title | Insider Code (Reg. O) | ||
| First Name | Jeffrey | Full Name | Jeffrey E Epstein |
| Middle Name | E | Gender | Male |
| Last Name | Epstein | Date of Birth | [REDACTED] |
| Suffix | Primary Country of Assets | UNITED STATES | |
| PreviousName/MMN/Allas | |||
| Citizenship | UNITED STATES | ||
| Employer Name | Self | High Risk Jurisdiction | No |
| Occupation | Entrepreneur | Industry Code (NAIC) | Individuals [999940] |
| Years at Occupation | 0 | Secondary Industry Code (NAIC) | Personal Investment Companies [525997] |
| Address(es) | ||||||||
|---|---|---|---|---|---|---|---|---|
| Type | Notes | Address | City, State, Postal Code | Country | Tools | Entered by | Date of Update | Preferred |
| Legal | 6100 RED HOOK OTRS STE B3 | ST 00802 | VIRGIN ISLANDS, U.S. | Map It | BATCH | 08/03/2012 | Yes |
| Phone(s)/Fax(s) | |||||||
|---|---|---|---|---|---|---|---|
| Type | Notes | Phone Number | Tools | Entered by | Date of Update | Preferred | |
| Home | [REDACTED] | Verify Do Not Call List | BATCH | 02/22/2013 | Yes | ||
| Work | [REDACTED] | Verify Do Not Call List | ROSALIA CRACCHIOLO | 05/12/2011 | No | ||
| Work | [REDACTED] | Verify Do Not Call List | TECS_DATA | 05/21/2011 | No | ||
| Fax | [REDACTED] | Verify Do Not Call List | TECS_DATA | 04/30/2011 | No | ||
| Fax | [REDACTED] | Verify Do Not Call List | TECS_DATA | 04/30/2011 | No | ||
| Work | [REDACTED] | Verify Do Not Call List | SYSTEM | 05/12/2011 | No | ||
| Work | [REDACTED] | Verify Do Not Call List | BATCH | 03/08/2013 | No | ||
| Other | [REDACTED] | Verify Do Not Call List | SYSTEM | 03/18/2013 | No |
| Email(s) | |||||
|---|---|---|---|---|---|
| Type | Notes | Entered by | Date of Update | Preferred | |
| Other | [REDACTED] | BATCH | 03/16/2013 | Yes |
| Cost Center & Hierarchy | |||
|---|---|---|---|
| Client Status | Client | Client Type | Individual |
| Clknt Sponsor | JUSTIN D NELSON | New of Existing Client | Existing |
|---|---|---|---|
| Coat Center | (02753 -GREENWICH | ||
| Client Service Team | CHBG (DE)4 | Entity Type | Decision Maker |
| GIO | Paul SM | Portfolio Manager | |
| Trust Advisor | Investor |
| IdentifiCa iOn | ||
|---|---|---|
| Withholding Federal Status | I Demestc Certfied | WIthhokIng SSNMN 05V182006 Cerefication Date SSNR1NrEIN |
| Form of government issued identification obtained for the files Primary identification Number | Dr.ners L cerise | ued By VIRGIN ISLANDS. U.S. |
| Date Issued | 01/152010 | Expiration Date 01/202015 |
| Introduction and Wealth | |
|---|---|
| Introduction Type | Existing JPMorgan Client - Inside LOB |
| Net Worth of client($) | 500,000,000.00 |
| Introduction form of government issued identification obtained for the files 7 | Disks License | |
|---|---|---|
| Hall an employee of JP client in person? What independent background check, in addition to the in which the background check was conducted. (at least I must be selected) | Wealth Management met the Global Corporate Security (-GCE) background check, has been carried out? Check all that apply and provide the date | Yes JPMC Network |
| JPMC Network Date | 03112/2013 | |
| JPMC Network Comments | Jeffrey token is an existing client of PB, He is en active brokerage client across asset classes currently covered by the Finn’s GO desk. Jeffrey Epstein has been on irivesbnent advise. for numerous high net worth clients and also a personal investor Jeffrey is very accessible and wet known to the learn We have advised hie on investments as wet as estate planning opportunities. Jeffrey has continues to be wel connected across business chimaera Epstein is well known to several JPM PB employees and senior nuinnioroffli Including Jas Silky. The Purpose of this DOR 6 to reeesn our due diligence on Mr. Epstein. Mr. Epstein was convicted of a lobby charge in 20M Jos Staley conferred with | |
| Stephen Cutler and the decision was made to keep Mr. Epstein as a PS dent Mr. Epstein completed his sentence and probation In 2010 The relotorehip has boon reviewed with senior management and cconaliarkelegal on a few occasions OW the post year as news stores of Attic-ay’ s past are picked up. No new claims or stones have surfaced recently. |
| Politically Exposed Person | |
|---|---|
| Is the client a current or former Senior United States or Non-USA Official / also known as a Politically Exposed Person (PEP), related to a PEP, or closely associated with a PEP? | No |
| Source of Wealth/Financial Information | |
|---|---|
| Source of Wealth- Identify the clients source of wealth from the following list of options | Other |
| Which country(ies) is(are) the Clients primary Source of Wealth or Income derived? | UNITED STATES |
| Provide detailed and specific Information. | Epstein managed many for numerous high net worth timbers |
|---|---|
| nn of his Mn to The Financial Trust Company and based it in | |
| Client Net Worth a | 500000000.8 |
| Overall PB/PliVal relationship sire and type of accounts: | Jeffrey maintains a brokerage trading relatinsh4 across motion |
| Is | this ashen/4 client, what other LOB has a relationship with |
| of material events that may have occurred over the last year | |
| Additional Comments | WA |
| Expected Activity Deposit Account(s) | ||
|---|---|---|
| ” IV* .. — !Braict on . | ExPeciedAilede;Lienitc:, -: .. • | |
| , •• „ . Anticipated boiler Anconetintals : | ||
| cat:, Once is | ||
| Cash Withdrawals Check Deposts | Low (1-10) | .510.000 |
| Checks Paid Intoning Woes (Domenc) | Low (140) | S50.001 TO $100000 |
| °Legates; IMres (Domestic) Incoming Wits (International) OulgoingWires (International) ACH Deposes | Low (1-10) | $103.001 TO $500.003 |
| ACH Pawner% | Low 0.10) | $10.0.00 10 S30.000 |
| Internal Transfer (OebesCrodrts) Asset PurchasesSaies | Low 0.10) | >$1.000.003 |
What is the InhiatongoIng source of funding for the clients Deposit Account(s) ?¶
This a a annual review. The acCoult has already been funded_ Any ongoing source Of funding w.1 be iron assets obtained through personal two…Anent% and born internal trans/or of funds from pereonal account het al -PAtccgan. , _ ,¶
Operational/household checking accounts and custody account to hold money market funds. Epstein has a checking account in personal name and a large trading account for his company, Financial Trust Company LLC. Account is used for maintenance of his various homes and lifestyle expenses. Personal accts are primarily funded from Mr. Epstein’s personal investment entity (which invests mostly in JPM MM Funds).¶
Checking account is used for personal investments and to pay everyday and monthly expenses.¶
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.):¶
Compliance reviews activity regularly.¶
Was expected activity for the client modified in the transaction activity section of the KYC ticket?¶
Yes¶
If modified, explain.¶
Activity modified to reflect client’s current transaction activity.¶
Client Directed Asset / Brokerage Account(s)¶
| Transaction Types | Expected Activity Levels | Anticipated Dollar Amount Totals per Month |
|---|---|---|
| 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) | <$10,000 |
What is the initial/ongoing source of funding for the client’s Client Directed Asset / Brokerage Account(s) ?¶
This is an annual review. The account has already been funded. Any ongoing source of funding will be from investment growth and dividends.¶
What is the purpose/intended use of account(s)? Please provide a detailed description of how the Client Directed Asset / Brokerage Account(s) will be used by the client.¶
The purpose of the account is for investments, trading and wealth accumulation.¶
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.):¶
Compliance review activity regularly.¶
Was expected activity for the client modified in the transaction activity section of the KYC ticket?¶
Yes¶
If modified, explain.¶
The activity was updated to reflect the client’s current transaction activity.¶
Additional Client Information¶
Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.)¶
Jeffrey Epstein is an existing client of PB. He is an active brokerage client covered on the GRO desk. Jeff is well know to the integrated team and senior management. Jeffrey Epstein has been a money manager for high net worth individuals, entrepreneur and personal investor. The team has regular discussion with Mr. Epstein and he remains very accessible.¶
Mr. Epstein is well known to several JPM PB employees.¶
6-18-10: Mr. Epstein completed serving out his house arrest. We have met regularly with compliance and legal do discuss the reallionship and any potential reputational risk concerns. We continue to monitor the situation closely and monitoring the occasional news stories regarding Mr. Epstein and civil lawsuits and monitor closely money movement. Mr. Epstein is managing his own personal wealth.¶
January 27, 2011 update: A few news stories during 2010 connects Jeffrey Epstein to human trafficking. The coverage team along with Catherine Keating and William Langford all met to discuss the situation and agreed to enhance monitoring and document a discussion with the client. Jes Staley discussed the topic with Jeffrey Epstein who replied there was no truth to the allegations, no evidence and was not expecting any problems. We will continue to monitor the accounts and cash usage closely going forward.¶
We continue to monitor the relationship closely and no additional stories or allegations have surfaced recently and Jeffrey maintain a professional relationship with the PB and integrated team.¶
Comment History¶
| Stage Name | Creation Date | Entered By | Comment Preview |
|---|---|---|---|
| There are no comments entered at this time. |
Approval History¶
| Stage Name | Signoff Date | Owner SID | Owner Name |
|---|---|---|---|
| Banker Attestation | 04/26/2013 11:04 AM | U008568 | JUSTIN D NELSON |
| Market Manager Approval | 05/01/2013 11:53 AM | U117517 | TOWNSEND C [REDACTED] |
| Regional Direct( | 0501201305:15 | U09:463 | NALLIAM M SHERIDAN |
|---|---|---|---|
| AwnAS | PM | ||
| CEO Approval | 0596/2013 1023 | U234Sile | BONNIE KIM |