EFTA01582770.pdf

Tickers. 102238622 Acrourila Initialed Dates. 06222011 11:20 AM Client Name ELLMAX Account Title: Initialer: DEBRA WHITE ECU!. 0033845033 Account Typo: Initiating Team. PB FRCNT OFFICE LOB. P8 Final Risk Rating Standard Initial Risk Rating Standard GCS Report Requested Full Presents of Potential High Risk Indicators No GCS Grid Search Type ___- lAecurityService Details ifurther Review Required Company Information Information not confirmed for alma (Tax ID). Details included Yos in the attachment Corporate Records Information contimiod; details included In the attachment. No Other Database Searches (ROOMS/Fatima) No records were found. No Internal Database Search (CSSSIFPS) Internal database search revealed prior GSI research and the Yes following derogatory information was repelled, Several newspaper articles derailing the investigation conducted by Britain Serious Fraud Office against Robert Maxwell. He allegedly used pension funds to service debts, cover operating losses, Bantle in the foreign exchange markets. and support the stock of his publicly held companies The agency is also looking inlo a complaint from Swiss Bank Corp.. Much says it did not receive collateral for a $100 million loan to a small private Maxwell company. Newspaper article dated 12101!2000. which stated that Ch me Maxwells source of wealth is being classified as something of a my sleet Newspaper article dated 08109/1996 detailing the arrest of Ghislaine Maxwell on OW charges. Numerous newspaper articles derailing the criminal fraud charges brought against Kevin and Ian Maxwell (sons al Robert Maxwell). Newspaper article dated 6123(2005 detailing 'Robed Maxwell meappropnated funds from the companies under his control. According to the newspaper article. 'He pledged assets as securty for additional loans', but instead of ,delivenng the assets to the lender. he would simply sell the assets for cash. -For example. Bentz language school was supposedly sold to a Japanese publishing company, but the shares had previousH been pledged as security for loans from Swiss Volksbank and Lehman Brothers' State Coen Searches . No records were found. No Federal Court Searches No records were found. No Personal Particulars No additional research necessary. No Publications .No records were found. No Regulatory Sanctions No records wore found. No OFACControl Let Search A search of OFAC did not reveal any matches. No Negative or Inconsistent Information Yes GCS Red Dot Confidential Treatment Requested by JPMorgan Chase JPM-SDNY-00062336 EFTA01582770