EFTA01480623.pdf

Tickete 105258603 Account% Initiated Date 07/1312013 07:22 AM Chem Name HBRK Account Title Initiator JUSTIN D NELSON ASSOCIATES INC ECI Account Type Initiating Team PS FRONT OFFICE LOB PB Verify & Confirm for HBRK ASSOCIATES INC Final Risk Rating High Initial Risk Rating Standard GCS Report Requested Full Presence of Potential High Risk Yes Indicators Reason for Adjustment Reputations! - Convicted Felon Comments Summary of Risk Attributes Jeffrey Epstein was convicted of a felony charge in 2008. Jos Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB ckent. Mr. Epstein completed his sentence and probation in 2010. Please summarize any material changes Jeffrey Epstein is an existing client of PB. He is an active brokerage client across asset which have occurred with the client classes currently covered by the Firm's 010 desk. Jeffrey Epstein has been an within the past 12 months: investment advisor for numerous high net worth clients and also a personal investor. Jeffrey is very accessible and well known to the team. We have advised him on investments as well as estate planning opportunities. Jeffrey has continues to be well connected across business channels. Epstein is well known to several JPM PS employees and senior management including Jes Staley. Also. Mr. Epstein was convicted of a felony charge in 2008. Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB client. Mr. Epstein completed his sentence and embalm in 2010. The relationship has been reviewed with senior management and compliance/legal on a few occasions over the post year as news stories of Jeffrey's past are picked up. No new claims or stones have surfaced recently. Risk Updated History Creation Entered by Updated Previous Comment Date Risk Risk GCS Grid Search Type Security Service Details Further Review Required Company Information Information confirmed; details included in No the attachment. Corporate Records Information confirmed: details included in No the attachment. Other Database Searches No records were found. No (RDC/MtS/Factiva) Internal Database Search (CSSS/FPS) Internal database search revealed prior No GS8I research for Harry Boiler and nothing derogatory to report. State Court Searches No records were found. No Federal Court Searches No records were found. No Personal Particulars Information confirmed; details included in No the attachment. Publications Publications revealed nothing derogatory. No Regulatory Sanctions No records were found. No OFAC/Control List Search A search of OFAC did not reveal any No matches Negative cc Inconsistent Information No Banker Attestation Details As the client sponsor, I understand that I am primarily responsible for protecting the fine'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 I • eta - • ulat• stand• • Int. Please state your rationale for conducting business with this We are exiting HBRK and the Epstein relationship. client Comments Confidential Treatment Requested by JPM-SDNY-00002828 JPMorgan Chase CONFIDENTIAL SDNY_GM_00272026 EFTA01480623