EFTA01480915.pdf

Operationalrnousehok1 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 LW. Account is used for maintenance of his various homes and lifestyle expenses. Personal accts. are primarily funded from Mr. Epati, ri.., personal investment entity (which invests mostly in JPM MM Funds). Checking account is used lot 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 _he client based on the client relationship (purpose of accounts, occupation, business activity, etc.): Compliance reviews actrinty regularly. Was expected activity for the client modified in the transaction activity section of the WIC ticket? Yes If modified, explain. Activity modified to reflect client's current transaction activity. Client Directed Asset / Brokerane Account(s) Transaction Types Expected Activity Levels Anticipated Dollar Amount Totals per Month Cash Deposits Cash Withdrawal,. Check Deposits Chocks Paid Incoming Wires (Domestic) Outgoing Wires (Domestic) Incoming Wires (Intornaticoall 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 fund ng for the client's Client Directed Asset! Brokerage Accounts) ? 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 purposehntended 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 'cautery. Was expected activity for the client modified In the transaction activity section of the KYC ticket? Yes If modified, explain. The activity was upated 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 treerbistccy, public infonnation, websties, etc.) Jeffrey Epstein is an existing client of PEI. Me is an active brokerage client covered on the GIO desk. Jeff is welt know to the integrated team and senior management. Jeffrey Epstein has been a money manager for high net worth Indrviduals,entrepreneur and personal investor. the team has regular discussion with Mr. Epstein and ho romans very accessible. Mr. Epstein is well known to several JPA1PB employees. 6.18-10: Mr. Epstein completed serving out his house arrest We have met regularly with compliance and legal do discuss the realtionship and any potential reputational risk concerns. We continue to monitor the situation closely and monitoring the accessional 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 Wiliam Langford all met to discuss the situation and agreed to enhance monitoring and document a discussion with the clent 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 PS and integrated team. Comment History Creation Date Entered B Comment Preview There are no comments entered et lin lime. Approval History Stage Name Signori Date Owner SID Owner Name Banker Attestation 04/262013 11 04 AM Market Manager 05/012013 11:53 Approval AM Confidential Treatment Requested by JPM-SDNY-00003156 JPMorgan Chase CONFIDENTIAL SDNY_GM_00272354 EFTA01480915