EFTA01480828.pdf

Is this a Cash intensive business? (Cash-intensive No trusinessesdentities 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? aa. None of the above Is the Entity a Personal Holding Company (PHC) or Personal No Investment Company (PIC) located in an offshore Jurisdiction? Business Case Please specify why you are comfortable with this client given regularly reviewed by managementlrepulational risk commelee 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 Long sowing client relaInnship wl the Private Bank. was established, how it came to be in PB/PWM, client's association with other JPM LOBS. etc. Client known to whom ()Morgan employees), how well, and Integrated leahomor management. how long: Overall PB/PWM relationship size and type of accounts: Primarily investments, .5100 million. Is this a shared client, what other LOB has a relationship with No. 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 less than 5 years ago to discuss our Private Banking capabilities reason for the meeting? and to ensure we were doing everything possible to service the relationship Describe any significant changes in the clients information no matenal changes 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 No cash activity for the LLC period reviewed and explain the purpose r use of the funds: Wire Activity: Summarize client wire activity during the regular business activity • pay eppenses, pay venders, 3rd parties period reviewed and explain the purpose ( use of the funds, for services rendered including any international/cross border wires: Before answering the following question please review the Yes 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 Yes activity consistent with expected transaction activity? Was any unusual or potentially suspicious transaction No activity detected? Additional Comments WA Expected Activity Deposit Account(s) Transaction Types Expected Activity Levels Anticipated Dollar Amount Totals per Month Cash Deposits Low (1-10) <510.000 Cash Withdrawals Low (1-10) <$10,000 Check Deposits Law (MO) <510000 Checks Paid Low (1-10) <510000 Incoming Wires (Domestic) Outgoing Wires (Domestic) Incoming Wires (International) Outgoing Wires (International) ACH Deposits ACH Payments Internal Transfer (DebitslCredits) Low (1-10) 550,001 TO 5100000 Asset Purchases-Sales What Is the initial/ongoing source of funding for the client's Deposit Accounts)? Initial source of funding al $100 K veil be debited from the JPIA DOA A 739110438 -Jeffrey Epstein. This volt be an internal transfer Ongoing source of funding E vat continue to come from ArC I What is the purposeanteixled use of account(s)? Please provide a detailed description of how the Deposit Accounts) will be used by the client. Household expenses al the 358 El Brillo Way, Palm Beach FL 33480 properly. Credit Types of Credit Lino of Credi Anticipated Dollar Amount Totals per 1,000.00 Month What is the purpose/intended use of account(s)? Please provide a detailed description of how the Credit will be used by the client. Neptune LLC currently has a corporate credit card issued to Ihem. Monthly payment depends on monthly charges Confidential Treatment Requested by JPM-SDNY-00003056 JPMorgan Chase CONFIDENTIAL SDNY_GM_00272254 EFTA01480828