EFTA01656452.pdf

FinCEN I Financial Crimes Enforcement Network United States Deparunatt of the ricnuty 0919 L4091000 LE :VSEI BSAR Transcript BSA: 310001 50416250 and DCN: Filing Information Type of Report Initial Report Filing Date 07/13/2019 Received Date 07/13/2019 Entry Date 07/15/2019 Submission Method Electronic discrete filing Subject Information Subj•ct .f 3 : EPSTEIN Role Subject Subject Type Purchaser/Sender Individual/Organization Individual Last(or Entity) Name EPSTEIN First Name JEFFREY Gender Type Male Date of Birth SSN/ITIN Form(s) of Identification Identification Type Pass ion Identification Number Issuing Country Code US Address(es) Address Type Subject permanent/mailing address Street Address 6100 RED HOOK QUARTER B3 6100 RED HOOK QUARTER B3 - Enhanced City ST THOMAS ST THOMAS - Enhanced State VI VI - Enhanced ZIP Code 008021348 00802-1348 - Enhanced Country VI US - Enhanced Phone Number(s) Type Work Number Email(s) Occupation/Type of Business Executive/Southern Trust Co. Corroborative Statement to No Filer Relationship to Financial Institution TIN 941737782 Page 1 The enclosed mformatico was caected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Deportment of the Treasury regttations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chapter X. The mformation a sensitive n nature and is to be treated accadingly The information may be used only for a purpose consistent with a crennal. tax. or regulatory nvestigation or proceeding. or in the conduct of intelligence or counterntelligence activities. inclueng analysis, to protect against ntemational terrorism. See 31 U S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Fnancial Crrnes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the GSA must be treated with particular care given that they contain unsubstantiated allegations of pssuble criminal activity. akin to ccofidential informant tips. Unauthorized release of information collected wider the BSA may result in criminal or civil sanctions. EFTA01656452  FinCEN Financial Crimes Enforcement Network United States Departntait d the rtaouty OSZ9 1.409 1.000 IC VS9 BSAR Transcript BSA: 310001 50416250 and DCN: Subject Information Institution(s) Relationship of Subject Customer. Yes Affected Account(s) Account Number 41224708 Financial Institution TIN 941737782 Subject 2 of 3 : KAHN Role Subject Subject Type Purchaser/Sender Individual/Organization Individual Last(or Entity) Name KAHN First Name RICHARD Gender Type Male Date of Birth SSN/ITIN Form(s) of Identification Identification Type Passport Identification Number 477516497 Issuing Country Code US Address(es) Address 1 of 3 Address Type Subject permanent/mailing address Street Addres t Stat ZIP Cod Country US US - Enhanced Address 2 of 3 Address Type Subject permanent/mailing address Street Address City State ZIP Code Page 2 The enclosed nformatico was connected and disseminated under provision: of the Bank Secrecy Act (the SSA) and U.S. Depatment of the Treasury regaations implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The reformation a sensitive n nature and is to be treated accadingly. The information may be used only for a purpose consistent with a crtnnal. tax. or regulatory nvestigation or proceeding. or in the conduct of intelligence or counterntelligence activities. incluctn analysis. to protect against nternational terrorism. See 31 U S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Friancial Craws Enforcement Network or he authorized delegate. Suspicious activity reports filed under the GSA must be treated with particular care given that they contain unsubstantiated allegations of passtle criminal activity. akin to ccofidential informant tips. Unauthorized release of information collected wider the BSA may result in criminal or civil sanctions. EFTA01656453  FinCEN Financial Crimes Enforcement Network United Scams Department cite rtaauty 09Z9LP091.000IC.VSO BSAR Transcript BSA: 310001 50416250 and DCN: Subject Information Country US US - Enhanced Address 3 of 3 Address Type Subject permanent/mailing address Street Address City State ZIP Code Country US - Enhanced Phone Number(s) Phone Number 1 of 2 Type Work Number Phone Number 2 of 2 Type Mobile Number Email(s) Occupation/Type of Business Executive/HBRK ASSOCIATES Relationship to Financial Institution TIN 941737782 Institution(s) Relationship of Subject Customer. Yes Affected Account(s) Account Number Financial institution TIN 941737782 Subject 3 of 3 : SOUTHERN I RUST COMPANY INC. Role Subject Subject Type Purchaser/Sender Individual/Organization Organization Last(or Entity) Name SOUTHERN TRUST COMPANY INC. EIN 660779861 Form(s) of Identification Identification Type Other Identification Number 1217721L Other Text Secretary of State Issuing State Code VI Issuing State Virgin Islands, U.S. Page 3 The enclosed nformatico was cSected and disseminated under provision: of the Bank Secrecy Act (Me SSA) and U.S. Department of the Treasury regaations implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The nformation is sensitive n nature and is to be treats accadingly. The information may be used only fa a purpose con ustent with a crtnnal. tax. or regulatory nvestigation or proceeding. or in the conduct of intelligence or counterntelligence activities. incluctn analysis, to protect against ntemational terrorism. See 31 U S.C. 5311. The information carnet be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Fnancial Crnies Enforcement Netwakor his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passtle criminal activity. akin to confidential informant tips. Unauthorized release of information collected wider the BSA may result in criminai or civil sanction:. EFTA01656454  Financial Crimes Enforcement Network FinCEN I WM! Saws Department tithe hussy 091914091.000 LE .VS9 BSAR Transcript BSA: 310001 50416250 and DCN: Subject Information Issuing Country Code VI Address(es) Address Type Subject permanent/mailing address Street Address 6100 RED HOOK QUARTER B3 6100 RED HOOK QUARTER B3 - Enhanced City ST THOMAS ST THOMAS - Enhanced State VI VI - Enhanced ZIP Code 008021348 00802-1348 - Enhanced Country VI US - Enhanced NAICS Code 5221 NAICS Code Text Depository Credit Intermediation Phone Number(s) Type Work Number Relationship to Financial Institution TIN 941737782 Institution(s) Relationship of Subject Customer. Yes Affected Account(s) Account Number 41224708 Financial Institution TIN 941737782 Suspicious Activity Information Amount Involved $27,658,324 Date or Date Range of Activity 06/28/2019 - 07/10/2019 Money laundering Suspicious EFT/wire transfers Financial instrument or Funds transfer payment mechanism Foreign currency Activity Location Financial Institution Locatioi 1 of 1 No Branch Activity Involved Yes Type of Financial Institution Securities/Futures Subsidiary of financial/bank holding company Clearing broker-securities Primary Regulator SEC RSSD Number 1026641 Legal Name Charles Schwab & Co., Inc EIN 941737782 Address Address Type I Address where transaction occurred Page 4 The enclosed riformatico was caected and disseminated under pcoviziss of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regOations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chapter X. The riformation is sensitive ri nature and is to be treats accadingly. The information may be used only fa a purpose con ustent with a crrnmat. tax. or regulatory nvestigation or proceeding. or in the conduct of ntelligence or counterntelligence activities. inclucren analysis, to protect against nternational terrorism. See 31 U S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Frnancial Cranes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the GSA must be treated with particular care given that they contain unsubstantiated allegations of paystale criminal activity. akin to ccofidenhal inform ant tips. Unauthorized release of information collected wider the BSA may rezult in criminS or civil :miens:. EFTA01656455  FinCEN I Financial Crimes Enforcement Network United Sfax Department a the Timuty 0919140910001E VS9 BSAR Transcript BSA: 310001 50416250 and DCN: Activity Location Street Address 211 Main St 211 MAIN ST - Enhanced City San Francisco SAN FRANCISCO - Enhanced State CA CA - Enhanced ZIP Code 94105 94105-1905 - Enhanced Country US US - Enhanced Internal Control File Number CA111517 Filer Information Primary Regulator Federal Reserve Filer Name The Charles Schwab Corporation EIN 943025021 Address Address Type Reporting party address Street Address 211 Main St 211 MAIN ST - Enhanced City San Francisco SAN FRANCISCO - Enhanced State CA CA - Enhanced ZIP Code 94105 94105-1905 - Enhanced Country US US - Enhanced Type of Financial Institution Other. Savings and Loan Holding Company RSSD Number 1026632 Internal control/file number CA111517 Contact for Assistance Full Name AMLI - AML Investigations Phone Number Phone Type Work Law Enforcement Information No Law Enforcement Information Available Page 5 The enclosed eformaticn was collected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury reguLations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chwter X. The eformation is sensitive at nature and is to be treated accordingly. The information may be used only la a purpose consistent with a crime* tax. or regulatory evestigation or proceeding. or in the conduct of anelligence or counteranelligence activities. induding analysis, to protect against international terronsm. See 31 U.S.C. 6311. The information cannot be further released. disseminated. dixtozed. or transmitted without pior approval of the Director of Financial efilTICS Enforcement Netwak or his authorized delegate_ Suspicious activity reports fled under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passable criminal activity. akin to ccadenbal informant tips- Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. EFTA01656456  FinCEN I Financial Crimes Enforcement Network United Said Dept IIIICI1C aJ the Treasury 09Z91.17091.000 IC :VSEI BSAR Transcript BSA: 310001 50416250 and DCN: Narrative This SAR is being filed by The Charles Schwab Corporation on behalf of Charles Schwab & Co., Inc. (*Schwab"), a registered broker dealer, to report concerns with attempted wires for the purpose of real estate, in light of negative media surrounding Jeffrey Epstein. The concern relates to an upcoming bail hearing for Mr. Epstein and stated concern regarding Jeffrey Epstein being a possible flight risk. This investigation is the result of an internal referral. Please refer to internal number CA111517 when requesting more information regarding this report. The three subjects of this SAR are: Southern Trust Company LLC who established a relationship with Schwab in April 2019 consisting of an active corporate brokerage account, 4122-4708. The company is registered in the United States (U.S.) Virgin Islands, license number 1-21-772-1L, as a business and management consulting firm, and was established in December 2018. Jeffrey Epstein (66 years old) established a relationship with Schwab in April 2019 and acts as an internal control person and beneficial owner on three accounts; the role does not grant him authority to act upon the Schwab accounts. Jeffrey Epstein is included as a subject of this SAR due to the negative media involving recent Federal charges. His disclosed employer is Executive at Southern Trust Company Inc. Richard Kahn (46 years old) established a relationship with Schwab in April 2019 consisting of three active corporate accounts. His disclosed employment is Senior Executive at HBRK Associates Inc. Richard Kahn appears to be a close business partner in various ventures with Jeffrey Epstein, including Southern Trust Company. The outgoing wires of concern were identified in the Schwab corporate brokerage account 41224708 registered to Southern Trust Company, Inc. Richard Kahn is the authorized agent, providing him the authority to act upon the account, and Jeffrey Epstein is listed as an internal control person and 100 percent beneficial owner; Mr. Epstein does not have any authority to act upon the account. Page 6 The enclosed nformatico was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFA Chyle; X. The nformation is sensitive n nature and is to be treated accadingly. The information may be used only Ice a purpose con ustent with a cone* tax. or regulatory nvestigation or proceeding. or in the conduct of ntelligence or countermtelligence activities. incluttn analysis, to protect against ntemational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Fnancial Crates Enforcement Network or his authorized delegate Suspicious activity reports fled under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passable criminal activity. akin to ccnklenbal informant tips- Unauthorized release of information collected wider the BSA may result in criminal or civil sanctions. EFTA01656457  -?.. -incEN I Financial Crimes Enforcement Network ' F' United Scams Deptmai( tithe Ttasusy 09Z9 Ii091.000 IC :VSEI BSAR Transcript BSA: 310001 50416250 and DCN: Narrative Schwab's investigation encompassed the time period ranging from 04/11/2019 to 07/10/2019. The activity in question occurred between 06/28/2019 and 07/10/2019, as referenced in Part II, line 30 of this SAR. The dollar amount $27,658,324.00, referenced in Part II, line 29 of this SAR represents the total amount of outgoing wires of concern which were identified during the investigation period. Jeffrey Epstein was arrested and federally charged on 07/08/2019 with one count of sex trafficking of minors, and one count of conspiracy to engage in sex trafficking of minors; allegations indicate that the activity took place between 2002 and 2005, possibly with an exchange of funds for acts. Jeffrey Epstein is being held in jail, with a scheduled bail hearing on 07/15/2019. Prosecutors consider Jeffrey Epstein a very high flight risk given his enormous wealth, international ties, and private planes. With the recent federal charges and concerns of flight risk, Schwab identified concerns with outgoing wires identified within the account of concern around the time Jeffrey Epstein was arrested and charged. On 06/26/2019, Schwab received a request to send an international foreign currency wire, the request signed by both Richard Kahn and Jeffrey Epstein, from brokerage account 41224708. The wire was requested for 11,150,000 Euros (EUR) or $12,708,324.00 (USD). The wire was remitted to Marc Leon located at Imm El Pacha 1st Floor 67 Rue IBN Khaldoun Marakech 4000 in Morocco. The funds were sent to an account at Bank Julius Baer and Co. Ltd. located in Zurich Switzerland, account number Research regarding Marc Leon identified that he is a partner at Kensington Morocco; the firm offers luxury properties in Morocco and France (www.kensingtonmorocco.com). The following day, 06/27/2019, Schwab received a call from Richard Kahn, asking if it was possible to terminate the aforementioned wire. The Schwab representative asked the reason for the reversal request, and Richard Kahn explained the reason was *for a concentrated real estate transaction, and uh, what uh, terms we were told we had on uh an agreement, were uh, Page 7 The enclosed eformaticn was colected and disseminated under provisions of the Bank Secrecy Act (Me SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seg.: 31 CFR Chapter X. The eformation is sensitive al nature and is to be treated accordingly. The information may be used only for a purpose consistent with a crineal, tax. or regulatory evestigation 04 proceeding. Of in the conduct of etelligence Of counteretelligence activitiesoncludeg analysis, to protect against eternabonal terrorism. See 31 U.S.C. 5311. The information carrot be further released. disseminated. dixlosed. or transmitted without pior approval of the Director of Feancial Crates Enforcement Network or his authorized delegate. Suspicious activity reports feed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of pa:cable criminal activity. akin to confidential informant tips_ Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. EFTA01656458  FinCEN I uFinancial Crimes Enforcement Network Mini lean Dept (malt at the Treasury 1:M9U/091000 IC :VS8 BSAR Transcript BSA: 310001 50416250 and DCN: Narrative not, were reneged on this morning. So uh, we are hoping it still can be a deal, but at this point the terms that I accepted are not agreeable, I want to retract the wire." The wire had been posted, and currency was exchanged. In order to reverse the wire, Schwab relayed to Mr. Kahn that it would be a "best effort" since the 30 minute window to cancel had lapsed. In the event Schwab was successful in reversing the wire, Richard Kahn agreed to assume any losses, but alluded that if there was a gain, he hoped he would receive the profit. Schwab was able to successfully retract the wire posted on 06/26/2019, and realized a ($113,527.80) loss after the currency conversion. The funds have been deposited back into brokerage account 41224708, registered as Southern Trust Company, Inc., on 07/10/2019. Richard Kahn indicated the wire for 11,150,000 Euro was sent prematurely, but that he may need to send another wire for even more to a different escrow account. This information was relayed during the conversations regarding the reversal request. On 07/04/2019, Schwab received a second international wire request, again signed by both Richard Kahn and Jeffrey Epstein; the request was to send S14,950,000 USD to Marc Leon located at Imm n The funds were sent to an account at Bank Julius Baer and Co. LTD located in Zurich Switzerland, reflecting an updated account number At the time of this request, the account did not have a balance to support the wire request as the retracted wire was still pending deposit back to account 41224708. Richard Kahn sent an email to Schwab five days later on 07/09/2019, asking to "please cancel this wire.' Once the retracted wire was posted to account 41224708 on 07/10/2019, Schwab made an outbound call to Richard Kahn where he confirmed he did not want the $14,950,000.00 wire to be processed. In addition, Richard Kahn asked the Schwab representative if future wire requests would require two signatures (note at this time Jeffrey Epstein was in jail). He indicated he would need to send more wires out soon Please see the attached CSV for detailed information pertaining to the outgoing wires. Page 8 The enclosed eformaticn was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chwter X. The eformation is sensitive a nature and is to be treated accordingly. The information may be used only for a purpose consistent with acrewet tax. or regulatory evestigation or proceeding. or in the conduct of etelligence or counteretelligence activities. inclueng analysis, to protect against eternational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prof approval of the Director of Feancial Crates Enforcement Netwodcor his authorized detegate. Suspicious activity reports fled under the BSA must be treated with particular care given that they contain unsubstantiated allegations of pasuble criminal activity. akin to ccnklenbal informant tips- Unauthorized release of information collected ruder the BSA may result in criminal or civil sanctions. EFTA01656459  Financial Crimes Enforcement Network FinCEN Unita! Sties Depas (mai r v the Irebury 09Z91.17091.000 IC :VSEI BSAR Transcript BSA: 31000150416250 and DCN: Narrative As of 07/10/2019, there have not been any funds remitted from the three accounts associated to Richard Kahn and Jeffrey Epstein, each established at Schwab in April 2019. The transactional review of these accounts discovered the accounts were funded by wire deposits and transfers of assets (TOA) from other financial institutions. Deposited funds were ultimately transferred to brokerage account 41224708 at Schwab. The three associated accounts were each initially funded with a $250,000.00 check deposit remitted from Deutsche Bank Trust or FirstBank accounts. The accounts they were transferred from were like-registered. Account 41224708 received a $2,000,000.00 wire from an external like-registered account to Southern Trust Company. In addition, brokerage account 11481413, registered to Southern Financial LLC received a wire deposit from Southern Trust Financial LLC ($2,000,000.00) and check deposits from Coatue Enterprises LLC ($39,800.00), and Darren Indyke & Michelle Saipher ($42,700.00). The memo on the check deposits noted promissory interest payments. The three accounts also received incoming investment account transfers from like registered accounts at TD Ameritrade and Merrill Lynch. As of 07/10/2019, various investments have been sold and the majority of proceeds have been transferred into brokerage account 41224708, used to fund the attempted outgoing wires. Schwab determined to file this SAR reporting concerns with international wires attempted to be remitted to an individual in Morocco for real estate purposes. In light of the negative media surrounding Jeffrey Epstein, including the upcoming bail hearing, Schwab is filing to report attempted money movement for an individual considered a flight risk. Schwab maintains all supporting documentation. Written requests for supporting documentation may be sent to . Please refer to internal number CA111517 when requesting more information regarding this report. Page 9 The enclosed eformation was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311. et seg.: 31 CFR Chapter X. The eformation is sensitive n nature and is to be treated 'secede*. The information may be used only la a purpose con ustent with a crime* tax. or regulatory Awe:ligation or proceeding. Of in the conduct of etelligence a counteretelligence activitiesoncludeg analysis. to protect against eternabonal terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. dixto--ed. or transmitted without pow approval of the Director of Estancia Crates Enforcement Netwarkor his authorized delegate Suspicious activity reports fled under the BSA must be treated with particular care given that they contain unsubstantiated allegations of pase.ible criminal activity. akin to cceiklenbal informant tips- Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. EFTA01656460