EXHIBIT 196 FILED UNDER SEAL¶
Ticket# Initiated Date 1605464792933 091112014 08.04¶
Client Name: D BLACK¶
Client Type: Individual¶
ECI• 0220700646¶
Banker: JUSTIN D NELSON (11008568)¶
LOB UHNW¶
Nationality: UNITED STATES¶
KYC Status. Complete¶
KYC Type- KYC Three Year Periodic Review¶
Primary Information¶
D BLACK - ECI: 0220700640, 9 W 57TH ST FL 41. NEW YORK, NY 100192701¶
Primary Information¶
Is the Client a JPMC employee’,¶
Front Office Restricted?¶
Normal¶
Prefix Title First Name Middle Name Last Name BLACK Suffix¶
Full Name Generation Previous Name / Alias Gender Male Marital Status Married¶
D BLACK¶
Date of Birth Mothers Maiden Name Country of Citizenship UNITED STATES¶
Primary country of domicile UNITED STATES Primary state of clornieire New York Primary country of assets UNITED STATES¶
I Is the Client a US Citizen?¶
Client Addresses¶
[Postal¶
I L.egal Address¶
I Title Company Name Mailing Label Salutation¶
Address 9 W 57TH ST FL 41¶
NEW YORK. New York 10019-2701 UNITED STATES¶
Conficentiel Address No¶
Phone¶
Work Extension This is a Call Back Number Yes¶
Notes¶
Work Extension This is a Call Back Numocy Yes¶
Tax¶
I Type of Tax ID¶
Seclal Security Number¶
ifdentificalion¶
Form of Government ID¶
I US DRIVER’S LICENSE¶
I ID Number¶
Social Security Number¶
MUM¶
Issued By Country¶
UNITED STATES¶
Issued By State¶
New York¶
Date Issued¶
07)1412009¶
Expiration Date¶
07/31/2017¶
aim* Cowrage¶
C lent Coverage¶
Decision Maker EC: 0220700646¶
Banker SID 0008568¶
Investor SD :U034450¶
Sion Maker Full Name D BLACK¶
Banker Full Name Client Service Team ID Client Service Team Name Cost Center Code JUSTIN D NELSON 400 CT/FINANCIAL LEADERS 002753 (DE) 12¶
investor PAUL S
¶
Introduction¶
C lent Introduction Details¶
were you Introduced to the client? 0¶
u Black Is a longstanding client of the private bank and very well known In the financial industry. Justin was originally introduced toll. I gh his family office head Eileen Alexander’s.¶
rWhat additionsl research have you done on the client, aside from meeting them in person’ I JPPAC Network 20 May 2008Apollo is an existing PBFSG client, -is the founding partner, we also did additional Internet research on the client and his company, AOlo and we found no negative media. i 1¶
I Has the banker or other appropriate officer of JPMorgan met the client In person? IYӦ
H¶
PIE P¶
Is the client a current or former Senior United States or Non-USA Official I also known as a Politically Exposed Person (PEP), related to a PEP, or closely associated with a PEP?¶
Source of Wealth / Financial Information¶
Which country(les) bgare) the Clients primary Source of Wealth or Income derived? UNITED STATES¶
iIs 10% or more of the wealth derived from assets, Investments or company ownership In any OFAC Sanctioned Countries? I No¶
Employment Status Employed¶
rSource(s) of Wealth - identify the clients source(s) of wealth from the following list of options¶
Employment, Income/F_amings *ern Client-Owned Business, Investments - Appreciation from Investable Assets¶
Employment¶
is this a private or public company? (If private, please list owners if public what is the ticker symbol?)¶
This is a public company traded on the NYSE, the ticker symbol is: APO¶
Describe the nature of the business and related operations. Also, provide information or where the primary operations are located Apollo is a private equity km who specialized in leverage buyouts, purchases of distressed securities, and corporate restructuring The headquarters Is located at 9 West 57th Street, New York, NY.¶
Approximate yearly income/salary/bonus/distribution personally derived from the business? 500.000,000 00¶
Investmon Appreciation from Investable Assets¶
be significant investment activities (Types of investments and investment vehicles such as stocks, bards, real estate.)¶
Black Invests in Na company’s funds which generates additional income.¶
Where did the money used to make the investment(s) originally come from and how long has the client been an investor?¶
The money originated from his employment and he has been an investor at Apollo for the duration of his time with the company, which is 21 years¶
Total Net Worth $5,000,000,000.00¶
What was the total net worth based on Magazine or News Article¶
Provide a detailed narrative of how the stated net wortrdsource of wealth of the client was verified. Please attach any suppordrg documentation to C¶
Black has been a long standing client of the private bank and is very well known In the financial InduStry. From 1977 to 1990 Mr. Black wo ed at Drexel Bumham Lambert where he was a Managing Director, head of the Mergers & Acquisitions group and co head of the Corporate Finance Department. In 1990 Mr. Black founded Apollo Global Management which focused on corporate restructuring, leveraged buyouts, and taking minority positions in growth oriented companies. In 2013 Mr. Black received approximately $546mm from his employment at Apollo. I have attached an article from the NYT that verifies and breaks down his wealth.¶
Expected Account Activiy¶
Product Family¶
Banking¶
Investments¶
Balking¶
Please provide a detailed description of the purpose/intended use of the Banking account(s)¶
it v11 be used for his daily living needs such as paying for heating arid electricity, housing expenses, dinners out. etc.¶
Please describe any significant transactions over the last 12 months, inuring any that we outside of the expected account activity previously documented for the client.¶
There are no significant transactions.¶
investments¶
Please provide a detailed description of the purpose/intended use of the Investment account(s)¶
j The intended use of this account Is for capital appreciation and income generation¶
!Please describe any significant transactions over the last 12 months, including any that are outside of the expected account activity previously I documented for the client.¶
There we no significant transactions.¶
The following questions apply to all accounts for this client¶
What is the initial source of funding for the client’s account(s)?¶
Investments: There was an Initial funding deposit in the amount of $10MM in August 2014. The deposit was a wire transfer from his account at Bank of America, account ff: 069 This money originated from his employment.¶
Savings: There are currently no funds in the account because it has not yet been funded. This is a new relationship for Justin Nelson. He is working on expending the re ’ ip with from investing to everyday deposiVbanking. The initial source of funding for the deposit products will Ikely be account 1005 here a JPM end will be in the amount of approximate y $500k and all of the funds will have originated from his employment.¶
i What is the ongoing source of funding for the client’s accouM(s)?¶
i The ongoing source of funding for all accounts will be external wires from the client’s previsou y stated Bank of America account, the funds from the BOA account will be generated from the client’s employment.¶
Wire Transaction Activity¶
What type of wire transfer activity is expected?¶
Same name US domestic¶
To send or receive funds for related extematAntemal accounts¶
Please include any additional pertinent information regarding wire activity.¶
IAutomatic Clearing House Transaction Activity¶
What type of ACH activity is expected?¶
Same name US domestic¶
What is the expected volume of Domestic ACH activity per month?¶
I 1-10¶
What is the anticipated va:ue (dollar amount) of Domestic ACH activity per month?¶
$50,001 to $100,000¶
The c iont will be using ACH for the following reason(s):¶
To facilitate payroll transactionsireceive employment compensation¶
To make payments (I.e. purchases, pay vendors, taxes, bills)¶
To send or receive funds for related extemalAntemal accounts¶
Please provide any additional pertinent information regarding the expected ACH activity¶
Cash Transaction Activity¶
How many cash deposits and withdrawals does the client expect to make each month?¶
1-10¶
What is the anticipated value (dollar amount) of Cash deposit and withdrawal activity per month?¶
$50,001 to $100,000¶
Will any deposits or withdrawals be made by or on behalf of third parties?¶
Where will the client access cash and currency services?¶
Branch/ATM deposits and withdrawals¶
Describe the type of Cash activity and the purpose/business rationale for the cash activity¶
Cash will be used for everyday, nomial daily activities such as paying for any expenses that may come up le: lunch, coffee, parking, etc.¶
Do you expect the cash activity to be routine for personal or business expenses?¶
1¶
Additional information regarding cash activity¶
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¶
Provide Client history/detail, Including when the relationship was established, how it came to be in UHNW/HNW, Client’s association with other jeaLOBS etc.¶
Bieck has been a long standing client of the private bank and Is very well known In the financial industry.¶
Client known to whom (JPM employees). how well and how long¶
The client Is well known to Justin Nelson and many other executives at J.P. he has been a client with the private bank for a long time.¶
Overall UHNW/HNW relationship size and type of accounts¶
He has 24mm h brokerage accounts with the bank.¶
Is this a shared cilenL what other LOB has a relationship with the client? Provide relationship manager name (if known). client of other LOB since (date) and relationship size?¶
None.¶
When was the last time you met the client? What was the reason for the meeting?¶
There is a meeting with this client scheduled for October 1, 2014.¶
Please include any additional information that would further explain your knowledge of the client (family treefhistory, public information, websites, etc.)¶
Al of accounts are In good standing.¶
Mr. Black is the Chairman of the Board, Chief Executive Officer and a Director of Apollo Global Management LLC and a Managing Partner of Apollo Management, L.P. which he founded in 1990 to manage investment capital on behalf of a group of institutional investors, focusing on corporate restructuring, leveraged buyouts, and taking minority positions in growth-oriented companies.¶
From 1977 to 1990, Mr. Black worked at Drexel Bumham Lambert incorporated, where he served as Managing Director, head of the Mergers & Acquisitions Group and co-head of the Corporate Finance Department. He serves on the boards of directors of Apollo Global Management, LLC, Sirius XM Radio Inc., and the general partner of AP Alternative Assets.¶
Mr. Black Is a trustee of The Museum of Modem Art, Mt. Sinai Hospital, The Metropolitan Museum of Art, Prep for Prep, and The Asia Society. He is also a member of The Council on Foreign Relations and The Partnership for New York City. Mr. Black is also a member of the boards of FasterCures and the Port Authority Task Forcei-traduated summa cum laude from Dartmouth College with a major in Philosophy and History and received an MBA from Harvard BusinessScrod.¶
Affirmation¶
As the client sponsor, understand that am primarily responsible for protecting the firm’s reputation from inappropriate business relationships, as well as prevent 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.¶
e state your rationale for conducting business with this client¶
has been a client and his accounts are in good standing. We are in the process of expanding the investment and credit relationship WI¶
Comments¶
The following is from Apollo’s website:¶
il Black¶
airman, Chief Executive Officer and Director¶
Mr. Black is the Chairman of the Board, Chief Executive Officer and a Director of Apollo Global Management, LLC and a Managing Partner of Apollo Management, L.P. which he founded in 1990 to manage investment capital on behalf of a group of institutional investors, focusing on corporate restructuring, leveraged buyouts, and taking minority positions in growth-oriented companies. From 1977 to 1990, Mr. Black worked at Drexel Bumham Lambert Incorporated, where he served as Managing Director, head of the Mergers & Acquisitions Group and co-head of the Corporate Finance Department He serves on the boards of directors of Apollo Global Management, LLC, Sirius XM Radio Inc., The New York City Partnership and the general partner of AP Alternative Assets.¶
Mr. Black is a trustee of The Museum of Modem Art, Mt. Sinai Hospital, The Metropolitan Museum of Art, Prep for Prep, and The Asia Society. He Is also a member of The Council on Foreign Relations. Mr. Black Is also a member of the boards of FasterCures and the Port Authority Task Force. He graduated summa cum laude from Dartmouth College with a major in Philosophy and History and received an MBA from Harvard Business School.¶
You are about to approve a high risk client. Have you included sufficient information to satisfy High Risk Enhanced Due Diligence regu atory requirements (Section 312 of the USA Patriot Act)?¶
Risk Factors and Indicators¶
Risk Factors.¶
No Risk Factors Present¶
Risk Indicators:¶
No Risk Indicators Present¶
Risk Rating¶
Initial Risk Rating¶
Standard¶
Fina Risk Rating¶
High¶
Reason for Adjusted Risk Rating¶
High risk - red dot - derogatory information¶
In July 8, 1991in the Federal Court in New York, Southern District, D. Black i r ed as defendant in a lawsuit against the investment bank Drexel Bumham Lambert by the Central Bank of Yugoslavia. From 77 to 1990 Black was employed by Drexel Bumham Lambert where he served as managing director, head of the Mergers & Acquisitions Group, anl co- ead of the Corporate Finance Department. The lawsuit alleges that the individual defendants, who were Drexel officials, are liable as *controlling persons’ for common-law fraud and negligent misrepresentation when the bank placed time deposits with the investment firm. Terms of the settlement are undisclosed.¶
***Several publications were found detailing various lawsuits filed against Leon Black. Apollo Management and several others. Some of the charges include breach of fiduciary duty, predatory pricing, violations of the [REDACTED]-Patman Act & securities fraud. News articles stated that Huntsman settled for $1bn to end its multi-billion dollar merger deal with rival Hexion. Hexion and its parent company Apollo Global Management LLC will have to pay Huntsman at least half of the damages on or before the end of the year, with the balance expected to be settled in end-March 2009. This settlement was brought after a lawsuit was filed by Huntsman against Apollo and its partners including [REDACTED] Black on claims of interference with the merger agreement between Huntsman and Basell. A news article from December 15, 2008 describes that the merger between Huntsman and Hexion Specialty Chemicals ended with Hexion’s owner Apollo Management paying more than $425 million in cash settlement. The merger fell through and sparked a string of lawsuits against Hexion, and Apollo. Along with the $425 million, Apollo will give Huntsman $250 million in 10-year convertible notes. [REDACTED] Black is listed as a defendant in a civil securities fraud-related class action suit filed in February 1992, titled “Presidential Life v. Milken Et Al”. There were 51 other defendants listed in the class action suit. The case is closed and the defendants had to pay $353,506 to the plaintiffs as a settlement. [REDACTED] Black is listed as a defendant in the civil securities fraud-related class action suit filed in June 1991, titled “The Equitable Life et al v. [REDACTED] et al”. There were 14 other defendants listed in the class action suit. The case is closed and the defendants had to pay $20,951 as a settlement in addition to the $322,762 from the Milken Civil Disgorgement Fund and $566,408 from the Milken Global Settlements Schedule 8 Fund. June 2000- Apollo Advisors, Marc Rowan, [REDACTED] Black and other defendants agreed pay approximately $1 million to settle a securities class action lawsuit.¶
***On January 30, 2002 California Attorney General Bill Lockyer named [REDACTED] Black and several companies in a lawsuit. The complaint alleges that as “principal” in Apollo Advisors [REDACTED] Black and his associates ran an international conspiracy used to illegally acquire assets held by the state and reap billions of dollars from the State of California and policyholders in the wake of the failure of Executive Life Insurance Company.¶
Report Requested from GSIInitialSummary of Risk AttributesHigh risk - red dot - derogatory information***In July 8, 1991in the Federal Court in New York, Southern District, [REDACTED] D. Black was named as defendant in a lawsuit against the investment bank Drexel Burnham Lambert by the Central Bank of Yugoslavia. From 1977 to 1990 [REDACTED] Black was employed by Drexel Burnham Lambert where he served as managing director, head of the Mergers & Acquisitions Group, and co-head of the Corporate Finance Department. The lawsuit alleges that the individual defendants, who were Drexel officials, are liable as “controlling persons” for common-law fraud and negligent misrepresentation when the bank placed time deposits with the investment firm. Terms of the settlement are undisclosed.¶
***Several publications were found detailing various lawsuits filed against [REDACTED] Black. Apollo Management, and several others. Some of the charges include breach of fiduciary duty, predatory pricing, violations of the [REDACTED]-Patman Act & securities fraud. News articles stated that Huntsman settled for $1bn to end its multi-billion dollar merger deal with rival Hexion. Hexion and its parent company Apollo Global Management LLC will have to pay Huntsman at least half of the damages on or before the end of the year, with the balance expected to be settled in end-March 2009. This settlement was brought after a lawsuit was filed by Huntsman against Apollo and its partners including [REDACTED] Black on claims of interference with the merger agreement between Huntsman and Basell. A news article from December 15, 2008 describes that the merger between Huntsman and Hexion Specialty Chemicals ended with Hexion’s owner Apollo Management paying more than $425 million in cash settlement. The merger fell through and sparked a string of lawsuits against Hexion, and Apollo. Along with the $425 million, Apollo will give Huntsman $250 million in 10-year convertible notes. [REDACTED] Black is listed as a defendant in a civil securities fraud-related class action suit filed in February 1992, titled “Presidential Life v. Milken Et Al”. There were 51 other defendants listed in the class action suit. The case is closed and the defendants had to pay $353,506 to the plaintiffs as a settlement. [REDACTED] Black is listed as a defendant in the civil securities fraud-related class action suit filed in June 1991, titled “The Equitable Life et al v. [REDACTED] et al”. There were 14 other defendants listed in the class action suit. The case is closed and the defendants had to pay $20,951 as a settlement in addition to the $322,762 from the Milken Civil Disgorgement Fund and $566,408 from the Milken Global Settlements Schedule 8 Fund. June 2000- Apollo Advisors, Marc Rowan, [REDACTED] Black and other defendants agreed pay approximately $1 million to settle a securities class action lawsuit.¶
***On January 30, 2002 California Attorney General Bill Lockyer named [REDACTED] Black and several companies in a lawsuit. The complaint alleges that as “principal” in Apollo Advisors [REDACTED] Black and his associates ran an international conspiracy used to illegally acquire assets held by the state and reap billions of dollars from the State of California and policyholders in the wake of the failure of Executive Life Insurance Company.¶
GSI ReportCurrent Report Type:FullMain Client Report Type:InitialGSI GridSearch TypeFurther Review RequiredCompany informationInformation confirmed; details included in the attachment.NoCorporate RecordsInformation confirmed; details included in the attachment.NoOther Database SearchesClient List Screening research revealed records found for [REDACTED] D. Black. No Google searches revealed records found.¶
Internal Database Search (SPEADD/FPS)Internal database search revealed prior GDDO research for [REDACTED] D. Black and the following derogatory information was reported. Several publications were found detailing various lawsuits filed against [REDACTED] Black, Apollo Management, and several others. Some of the charges include breach of fiduciary duty, predatory pricing, violations of the [REDACTED]-Patman Act & securities fraud. News articles stated that Huntsman settled for $1bn to end its multi-billion dollar merger deal with rival Hexion. Hexion and its parent company Apollo Global Management LLC will have to pay Huntsman at least half of the damages on or before the end of the year, with the balance expected to be settled in end-March¶
against Apollo and its partners including Black on claims of interference with the merger agreement be een Huntsman and Basel/. A news article from December 15, 2008 describes that the merger between Huntsman and Hexion Specialty Chemicals ended with Hexion’s owner Apollo Management paying more then $425 million in cash settlement. The merger fell through and sparked a string of lawsuits against Hexion, and Apollo. Along with the $425 milli Ilo will give Huntsman $250 million in 10-year convertible notes. Black is listed as a defendant in a civil securities fraud-related class a suit filed in February 1992, titled ‘Presidential Life v. Milken Et Al’. There were 51 other defendants listed in the class action suit. The case is closed and t .i fondants ° had to pay $353,506 to the plaintiffs as a settlement¶
Black is listed as a defendant in the civil securities fraud-related n suit filed in June 1991, titled ‘The Equitable Life et al v et al”.There were 14 other defendants listed in the class action sui case Is closed and the defendants had to pay $20,951 as a settlement in addition to the $322,762 from the Milken Civil Disgorgement Fund and $566,408 from the Milken Global Se ts Schedule 8 Fund. June 2000- Apollo Advisors, Marc Rowan, Black and other defendants agreed pay approximately $1 million to se ea securities class action lawsuit.¶
Reference the account titled ‘Apollo Total Return Management LLC’ (attach document labeled 9150543148) for previous research.¶
| Court Searches | |
|---|---|
| Information confirmed; details included in the attachment Personal Particulars Information confirmed; details included in the attachment Publications Information confirmed; details included in the attachment Regu’atory Sanctions | Yes No Yes |
| No records found. ()FAG/Control List Search | No |
| Client List Screening research did not reveal any OFAC matches. | No |
| GSI Red Dot | |
|---|---|
| Has this been identified as Red Dot KYC? | Negative or inconsistent Information |
| Yes | Yes |
Details (Include KYC names in which this was previously reported. T n 0¶
In July 8, 1991in the Federal Court in New York, Southern District, D. Black was as defendant in a lawsuit against the investment bank Drexel Bumham Lambert by the Central Bank of Yugoslavia. rom 1977 to 1990 Black was employed by Drexel Burnham Lambert where he served as managing director, head of the Mergers & Acquisitions Group, and co- ead of the Corporate Finance Department. The lawsuit alleges that the individual defendants, who were Drexel officials, are liable as “controlling persons” for common-law fraud and negligent misrepresentation when the bank placed time deposits with the investment firm. Terms of the settlement are undisclosed.¶
Please respond to any issue identified in the GS&I grid that either needs further review or red dot which is not already covered in Business Case within the KYC¶
This event happened a long time ago. Also, MI is well known to the firm. We offer Apollo funds on the PB platform and both Apollo and MI have gone through extensive due diligence.¶
| Audit Trail | |||
|---|---|---|---|
| Date I Time Stage 09/16/2014 08:22 Compose 10/03/2014 16:47 Banker Attestation | Owner Name AMANDA SILVER (N618783) JUSTIN NELSON (U008568) | Team Onboarding Owner KYC PB ATTESTORS | Detail Initiated Ticket Approved Client |
| 10/06/2014 13:58 Market Manager Approval | TOWNSEND (U117517) | KYC PB MARKET DIRECTOR | Approved Client |
| 10/06/2014 17:08 Region’. Director Approval | WILLIAM SHERIDAN (U095553) | KYC PB CEO DIRECT REPORT | Approved Client |
| 10/08/2014 08:30 LOB CEO Approval | JOHN DUFFY (U093971) | KYC PB CEO | Approved Client |