EFTA01269520.pdf

Ill First Bank Document Checklist for Business Accounts File Together we are one Important note: Please refer to the Account Opening Procedures for specific information on the various types of documents required at account opening. Account Title: I Account Number: Date Opened: '1:311 1,,c2 Check El if Is completed General Documents or Remarks es)::„d , i NIA If not applicable Signature Cards r., Client Due Diligence Easiness Accounts vy Due Diligence for High Risk Business Accounts (Checklist) o," Observations al Place of Business 2> OFAC9LC (pint evidence of verification) Document Checklist for Business Accounts File ...-7 Appropriate W-8 Form (if non-U.S. entity) Disclosures that must be given to client: USA Patriot Act Customer Information Program Notice ...---- Rates and Fees Schedule k--- Account Agreement 4...- ,.....- FDIC Insuring Your Deposit Brochure (USVI only) NOM of Negative Information Disclosure ..--- First BanCorp Information Sharng and Privacy Policy fr." Check EI if is completed Other Documents or Remarks WA if not applicable fitalifilitankranalaitiaitiltairty. , vratia -Ziertetteoe ,,,,4witZ,r1 Cake* of Incorporation or Certificate ol Clualfration (A a U.S based corporation) Business/Trade License (current) Cerofrate of Good Standing Arodes ol incoroorason (stamped by the Office ol the lieutenant Governor if USVI and ere Registrar olComparies ki the BVI) Certificate of Trade Name Corporate Resolution (with Corporate Seal) Corporate Resolution and Corporate Authorization and Indemnity Agreement for TelephonelTelex/Facsimile/Written Instructions. (This document is only required if client requests fund transfers by phone fax or messenger) • O.. •( 0 I'L.-e ,- “ Partnership Letter and Searrip Agreement Business/Traderipens° (current) Partnership Agreement (A it exists) Cerbfr.ate of Trade Name (it appricabie) Cenificate of Limited Partnership (il applicable) Resoknon where Partnership contains Corporation as a Partner (il appwaleot Partnership Contain Limited Gadfly Company as a Partner (A apphcatle) Partnership Calains Trust as a Partner (il meltable) Pannershoecntains Joint venture as a Partner (1applicable) Seco* Procedure Agreement tor TehiphonerFar Issuance of Payment Orders or Request for international Drafts Fl requested) _. Sole Propriebr Agreement (Individual) Sole Proprietorship Multi* Authorized Signers (if apt:arable) Businessgrale License (current) Calera of Trade Name (il applicable) Secunty Procedure Agreement for Teleptone'Fax Isspance of Payment Orders a Request for liternational Draft (if requested) .:., 7.7C‘c!7;-• 2. riWi'W,T,;Tt2:31,..., 2;:tfiff...1n1-2711,31:742,-;sr,-,Issitdi.,...L._— 1....„--I;NcL,. ..- Unincorporated AssociatInn Resolution (signed by the .......•_•__•._..• Secunty Procedure Agreement for Telephone/Fait !sue erviispENTIAL ) SONY GM_00013710 irstban EFTA_DO 24053 EFTA01269520  cri fat ItafM cfalleWi lfge*NDOMM Limited Liability Company Letter and Secunty Agreement Business/Trade License (anent) Operating Agreemert Amdes of Organriaten or Certificate of Fcemation (nor-bank form- a me PLLC a anew Ptt.0 Cerefrate of Existence Sectay Procecure Agreement for Teleohonafax Issuance of Payment Orders or Request for International Drafts (1requested) -B taincorporated Limited Labia Company Contains Corporate ktmbevMsnager (4 applicable) Limited Liability Comeau Conlon Limited Liability Company as a MemberMarager (4 apt:doable) Limited Liability Company Contans Limited Liabity Partnership as a Member/Manager (if enAt-able) Limited Liability Company Contains Partnership as a MemberiManager td applicable} Limited Liability Company Contains Trust as a Priemberktanager (it applicable) Limited Liability Company Unincorporated Association as a Mentedllanager (t writable) Limited Lability Company Contains Joint Venture as a MentenManager (4 applicable) ., Corporate Resolution Certificate of Incorporatien or Certificate of Oualifirabon (d a U.S. based corporation) Artioes of Mcaporation (stamped by the Moe al the Lieutenant Gaynor) BusinessfTrade License (current) Corporate Resolution and Corporate Authorization and Indemnity Agreement for Teleftwnerfelex/FacsimileNVritten Instructions. (This document is only required if client requests fund transfers by phone, fax or messenger) United Liability Careen) Letter & Secuity Agree-nent Business/Trade license (Centre) i I 4( it f;.'::. : -i- /1.'1 , 1: ,(, 11•,,,„ , Certificate of Trade Nam (If applicable) CACI Operating Agreement Articles of Organization cr Certifesate of Pamela:in (non-bank tom-required it lie LW is a 'nevi / LW) Certificate of Existence Sean* Ptocedure Agreement for Telephone*ax Issuance of Payment Orders a Request to Intentationel Drafts (it requested) Limited lethally Company Cortex.* Corporate litemberiManager(d applicable) Limited Liability Company Contains Limited Liability Canpany as a Member/Maragei (il applicable) Limited Leaky Germany Conan Limited Lability Partnership as a Member/Amager (if applkable) Limited Liability Company Contain Partnership as a klemtertmanagee (it applicable) Limited Lebrity Company Cor4ahs Tiust as a Membecilitarager (A applicable) Limited Liability Comely Contains Unincorporated Association as a MemberManager Of applcable) Limited Liability Company Contains Joint Venture as a lAemberiblaneger (d applicable) b e - tit ...1.fizy x Limited Liabitty ParinersIV Letter and Security Agreement Celt:foaled Limited Parinersip (Limeed Pamership) - Not required when opening accounts for law firms or secunty brokerage 60uSes Cerbfrate of Existerce Businessrfrade License (current) Operating Agreement Statement of Clualkation or Statement of Foreign Qualification Certificate of Trade Name (4apotuable) Security Procedure Agreement tot Terephcoefax Issuance of Payment Orders or Request for International Drafts (V requested) Limited Lability Partnership Contains United Liability Company as a klembetiMariager (fil applicable) tinted Liability Partnership Contains Limbed May Partnershp as a Memberiblanaget (d applicable) Limited Liability Partnership Contains Partnership as a MenterlAanager Of applicable) Notice of Appointment (Court Order or Court Appointment Papers) Security Procedure Agreement for Telephoneax Isscance of Payment Orders or Request for International Drafts (4 requested) SONY_OM_00013711 AICI . —..—.— —..—... EFTA_00 I 24354 EFTA01269521  iu If the PAC is an Unincorporated ASSCCaten, then a leder signed by the presided of the assocabon NatPI the association purpose and an UnonanDrab9d Associaton Resokiton rewired It Me PAC's a Nof for profit Ciorpotatign, a Certificate ol Incorporating fora Nen-Clod( Corporation is moored A cergficalion hen the Virgin Islands Board of Elections Check El if is obtained or Remarks Additional Documents (supporting documents) WA if not applicable Bureau Report OCreds °Other In-house Bank Reference Other Banking References Income dedication Professional association amnion litarketinprochures. business Web site and other market media See Photos, Unities rooms (itater,sleckaity. telepficno) Sample ol entity stationery (presentation card, letter head paper, envelopes...1 Other: _Other: _Other: Other:_ Other. Other: Other: OR ACCOUNT REFERALS ONLY: If this account opening was referred by a Department's Officer, other than the Branch's Officer, please fill out the following certification. This account was referred by (name) (title) of (Department) to be opened at Branch. I certify that I complied with the Customer Identification Program aid reviewed this customer's profile and supporting documentation in compliance with the Customer Due Diligence and Enhance Due Diligence processes. Name & Title Signature Date SDNY_GM_00013712 CONFIDENTIAL CONFIDENTIAL FirstBankPR000875 EFTA_OOI 24355 EFTA01269522 DUE DILIGENCE FOR HIGH RISK BUSINESS (CHECKLIST) I First Bank Together we are one Account Title Account Number: FSF, LLC 7322000576 High Risk Business require additional due diligence. If more than one type of business applies. then follow the requirements for all the types of business that does apply. Some Hioh Risk Businesses require the completion of the "Observation at Place ob Business Form". If a Business is under construction or the client has not yet established a 'facility' and our Manager must approve the delay in completing the Observation Form. All 'high risk' business is not necessarily listed below. If you believe a business to be 'high nsk'. and it is not listed below, you must contact BSA Compliance Office for direction and guidance. Where BSA Compliance consultation or approval required, the requirement cannot be waned. BUSINESS TYPE REQUIRED ACTION O Financial Institutions (Credit Union. Commercial and Pnvate Lencers, Note: FIRSTBANK does not open account for money transmitters or Mortgage Brokers, Private Bank and National Bank) check cashing business. ❑ Non-Bank Financial Institution (Currency Exchange, Foreign Exchange O Operating accounts for Financial and Non-Bank Institutions Do not require and Casino) the approval of FirstBank's BSA Compliance Department. In this case you will: — Need a letter form the customer on company letterhead — Staling the account is for operational purposes only. and — No customer funds will flow through the account. — Third parties cannot fund operating accounts O The BSA Compliance Officer approval required prior to opening for all other typos of accounts. Call 787-993-5150. O Cash Intensive Business (Any retail business whose transaction Profile O Visit the place of business and complete the 'Observations at the Place of shows $30,000 or more in cash per week and who is not a recognized Business' form. This must be done within 4 weeks of account opening. If regional or national chain, e.g. Walgreens, TGI Fridays. Chills, Amigo. the business is no located in you marketplace (i.e. Customer lives in etc.) Ponce and open an account in Hato Rey Branch) the Bank Office opening - Foods and chinking places the account must indicated the reason for opening the account at Branch on the Observation. at trio Place of Business Form and why this - Grocery Stores explanation makes business sense. - Beer. wine and liquor store - Art dealers O ATM Verify if privately owned ATMs are located on the premises. If yes, obtain copy of Third Pasty Agreements. - Vending Machine Operators O If the business sells monetary instruments (money order) and/or prepaid O Telecommunications/ Phone Cards/ Telephone Centers cards, obtain copy of the Sales Agent Agreement. O Travel Agency O Import/ Export Business (Physical Inventory in store or warehouse can be observed) O Jewelry/ Genii Precious Metals O Electronics (who'esale) ❑ Gas Stations O Gambling/Gaming Establishments (" 20% of the activity) O Import/Expon Broker (never takes possession of goods. either home base Obtain at least 2 or more of any of the following (copy for the file) or no physical location accessible to demonstrate business) O Invoices O Used Car Sale (no sales location) O Shipping documents O Freight Transportation O Contracts O Transit and Ground Transportation These must be supportive of the volume of business anticipated in the ❑ Off-Shore Corporations (review the Articles of Incorporation. If Corporate Transaction Profile. For example: If a company indicated that wires in Structure uses 'bearer shares' do no open the account). Under no $200,000 range will be received, 2 invoices for $460 are not acceptable. circumstances may the business be incorporated in a financial haven country. See for a listing of theses countries. O Car/Boat/ Plane Dealership Sample IRS Fenn 8300 for review. If customer indicates cash sales do not O Stock Brokerage exceed $10,000 to a customer, indicate this on the Observations at the Place of Business form. Visit the place of business and complete the 'Observations at the Pace of Business' form. This must be done within 4 weeks of account opening. It the business is no located in you marketplace (i.e. Customer lives in Ponce and open an account in Caguas) the Bank Office opening the account must incficated the reason (or opening the account at Branch on the Observation, at the Place of Business Form and why this explanation makes business sense. O Foreign Business no registered to do business in the United States Note: At present. FIRSTBANK does not open accounts for foreign (including Puerto Rico). United States Virgin Islands, or British Virgin business not registered to do business In the United States. Islands ❑ Internal Business — Any business that sells the majority of its goods and You must review the website to ensure that there Is no Information that could services over the Internet (Not a retail outlet that also has a web page). result in embarrassment or negative publicity for FIRST BANK. (Examples: adult entertainment. pornography. etc.) O Personal Investment Company tin •-r its i iestment busingewjsc nateggigqihtopproval of O Investment Management Business C' ONFIDENTIAL - CONFI I n . h case. you will need: — - ter fen rnennony letterhaerl etaHnn the anneint FirstBankPR000876 EFTA_00124356 EFTA01269523  BUSINESS TYPE REQUIRED ACTION O Nome Based Business Obtain any two (2) of the following (copies for filo): O Legal Services • Invoices forte supple's O Accounting, Tax Preparation. and Payroll Services • Contracts with customer O Computer System Design and Related Services • Telephone verification with customers in lieu of contracts • Copy of a license to engage in a particular business (if required by your state) Any document from a third party to the ownedegnedbusiness evidencing that the business is engaged in the activity they claim which can be verified by telephone. If the business owner has maintained his personal checking account of another business account with First Bank for 6 month or more or longer. The Branch Manager may waive the requirement for invoices/ contracts. etc. If deemed prudent to do so. The following information must be documented in the accountketabonship filo. • Owner's name • Customer or other business account number • Date opened Branch management must provide a justification memo to be kept on file O Business Accepting thirdparly checks explaining the reason for opening the relationship. This justification should clearly indicate the relationship between the Branch customer and the third party whose checks are being deposited. All reevant documentation. e.g. Customer Due Diligence (CDD) Profile, customer contractual agreements, a listing of the businesses' customers. etc. must be sent with the justification memo. Needs the approval of the Branch Manager. ❑ Embassies/Consulates and other Representative Office of Foreign O The BSA Compliance Officer approval required prior to opening these Governments types of accounts. Call 787-993-5150. O Charitable Organizations. Not for Profits and religious Organizations Obtain the following information and document in the observation at piece of - Religous Organizations business document (copies on file): - Grant making and giving services • Purpose and objective of their activities - Civic and Social Organizations • Organization structure • The donor and volunteer base • Funding and disbursement criteria • Large contributors • Affiliation with other Charitable Groups • Fundng end disbursement criteria O Initial Deposit greater Than S600K The Source of Wealth must be determined and recorded. Refer to Guide for Ft )1pave reviewed the customer profile of this prospect and determined that thl Is not a high risk business and the nt opening request was: Approved O Denied (Reason): 0 Approved subject to: Illaciatut at, Business Manager Name/Officer in Charge Signa to This account was classified high risk business and the account opening reques 5: • Approved O Denied (Reason): O Approved subject to: Business Manager Name/Officer in Charge Signature Date SDNY_GM_00013714 CONFIDENTIAL CONFIDENTIAL FirstBankPR000877 EFTA_00124357 EFTA01269524  Due Diligence For High Risk Individuals (Checklist) First Bank Together we are one Account Title: Account Number: Jeffrey Epstein High Risk Individuals require additional due diligence. Examples of High Risk Individuals are Nonresident Aliens, Foreign Individuals and Politically Exposed Persons. Where BSA Compliance consultation or approval required, the requirement cannot be waived. O Nonresident Aliens and Foreign Individuals Accounts where Nonresident Aliens and Foreign Individuals have a substantial ownership Interest the following procedures shall be followed: • Requiring current passport, accompanied by a current visa. form non citizens. • Comparing the individuals country of origin to current "high risk" jurisdictions. • For people with permission to work in U.S., assuring that the W8-BEN reflects an SSN. • Inquiring about the destinations and sources of financial transactions involving foreign countries. • Inquiring as whether he/she is a 'Foreign Public Figure' or 'Related Individual'. • The following individuals must approve the account opening: ❑ Branch Manager El Foreign Public Figure/ Related Individuals Additional requirements for foreign public figures (FPF), or related individual, or legal entities in which public figures or O A 'Public Figure' is any foreign (non US-citlzen) vitro related individuals have a substantial ownership interest the occupies or recently occupied, is actively seeking or is following procedures shall be followed: being considered for a senior position in a government (or political party), or any department (including th • The sources of wealth must be determined and recorded. Refer to Guide for Instructions. ID Senior foreign executives of foreign government- owe military), agency, or instrumentality thereof. nod An inquiry must be made as to the reputation of the FPF or corporations are also considered public figures. related individual. ❑ A "Related Individual" is a member of the immediate Rem contact BSA Compliance to perform a World Check family of a public figure (e.g., a spouse, parent, sibling, search. or child) or a senior advisor closely associated with a public figure. • The following individuals must approve the account opening: O Legal entities in which public figures or related individuals have a substantial ownership interest. ❑ Director of Sales and Distribution ❑ FirstBank BSA Compliance Unit O Initial Deposit greater than $100K • The sources of wealth must be determined and recorded. (Refer to GyidaTorinst ans I have reviewed the customer profile of this prospect and determined at this is not a high risk individual a4:1 the account opening request was: Approved El Denied (Reason): O Approved subject to: maid.. at. Business Manager Name/Officer in Ghee 0N Date CONFIDENTIAL FirstBankPR000878 EFTA_00124358 EFTA01269525  I First Bank Client Due Diligence Wpm Islands Business Accounts 1. Business Information Account Title ("Depositor'): FSF, LLC Account Number: S.S./TIN/EIN: Physical Address: Mailing Address: 6100 Red Hook Quarter Suite B3 Sarno St. Thomas, US Virgin Islands 00802 Business Telephone il Business Fax t IntemetWebsite Address: N/A Line of Business: Holding Company NAICS Code 550- COO Date Established: 10/21/2008 Annual Salos: se- 41lea) - Ntir. of Offices/Branches: 1 Nbr. of Employees: 0 Property Status: O Own 0 Lease Referred By: O Advertisement 0 Current Client • Other: Contact Person Name 8 Title: Jeanne Brennan Contact Person Teleran. II 2. Account Type • Sole Proprietorship O Partnership O Corporation O Non-Profs O LLP 0 LLC O Other • NI Commercial Checkivg O Arranged 00 O Convnercial Statement SV O Commercial Passbook SavIngs t;f0 o Commercial DBA Checking Checking s-,-/z O commercial Checking IOLTA O Arranged 00 Offshore (BV1) O Arranged OD OBA ['Government Statement SV • Commercial DBA Stalement SV • Commercial Maxmizer SV III Commercial DBA Maximizer SV O Goverment Passbook Savings O Certificate of Deposit O Other 3. Authorizer . . - • • • . .eachauth•rize•si•n-r.) --.- 7.-- Authorized Signer Name: Jeffrey Epstein Financial Member Profession: Consultant Corporate Tulle: .v-r; Physical (Home) Address: Personal Mailing Address: Little Saint James Island 6100 Red Hook Quarter B3 St. Thomas, US Virgin Islands St. Thomas US Virgin Islands Social Security Number. I Date Of Bah:1/20/1953 I Place Of Birth:New YOdc I Citizen Of-.USA Hem T I N liter. Rusin I n N mbar Business Fax Number: MOWetrkmber. . Email Address 4 Years n pat Photo Identification - Type 3 Number: VI Drivers License Identification euiratica Date: 01/20/09 ,-- (2/0FAC ISCHEXSYSTEMS called O Yes 0No, explain why: I O i SSN Response: Year. i qpi State: Yi ID Response: K _./...netiCASS-2A-, OPLC • BANK REFERENCE requested O Yes O No, explainivAir Response: 0 Check here if mere are additional signers on reverse side of the Cent Information Sheet (KYC) Business Accounts. 4. Account Agreement Acceptance and Taxpayer Status Certification The Depositor hereby certifies that the FirstBank has been designated as a depository of the depositor and that it has reviewed the information oontaned in this Client Information Sheet (KYC) and finds it accurate on this date. The Depositor has received and agrees to the Terms and Agreements for Commercial Accounts and Rates and Fees Schedule currently in effect and as may be amended for the type ol account and services It has selected. I Under penalties of perjury, the Depositor centres that (1) The number shown on this form is the correct lax identification number and (2) that the Depositor ! is not subject to backup withholding either because: (a) it has not been notified by the internal Revenue Service (IRS) that it is subject to withholding as a result of failure to report all interest or dividends, or (b) that the IRS has notified the Depositor that it is no longer subject to backup withholding or it is exempt from backup withnoldng. (3) the Depositor is a U.S. entity. (Cross out subpart 2(a) if it Is not true. If Statement 3 is not true, cross out and complete an appropriate Form W-8) The Internal Revenue Service does not require your consent to any provision of this document other than the Certification required to avoid backup withholding. .. Date Authorized Signature Title: (Secretary/IfreasuredCashied __ 10/23/2008 / e 2-Y ol Member 5. Initial Deposit Type: O Mgr CM/ O Other' Amount 'Mai • If the initial deposit is over $500,000 • Cash Money Order/ please document source of funds or source of wealth. (Refer to Guide for instructicns) Egi Check Travelers Chk to Transfer D. Expected Transactions (Monthly) ria •.a.• Inosnel tn elasWit rAeinite month earn ma re Il ' CONFIDENTIAL FirstBankPR000879 EFTA_00124359 EFTA01269526 Financial Institution: Financial II-81100n: First Bank 8. Additional Authorized Signers (Complete the following information for each authorized signer.) Authorized Signer Name: Profession: Corporate Title: Physical (Home) Address: Personal Mailing Address: Social Security Number: Date Of Birth: Place Of Birth: Citizen Of: Home Telephone Number Business Telephone Number. Business Fax Number. Motile Number. Email Address: Yews ii Occtoadon: Photo Identification Type & Number. Identification iration Date: 20 • OFAC CHEXSYSTEMS called M Yes O No, explain why: SSN Response: Year: State: ID Response: OPLC BANK REFERENCE requested Yes No, explain why: Response: Authorized Signer Name: ProJessica rate Title: Physical (Home) Address: Personal Mailing Address: / / Social Security Number. I Date Of Birth: Place Of Binh: Citizen Of: Home Telephone Number. Business Telephone Number. Business Fax Number. fr,tfle Number Email Address: Years n Candice: Photo Identification Type & Number. Identification Expiration Date: 25 0 OFAC CHEXSYSTEMS called • Yes O No, explain why: SSN Response: Year: State: ID Response: M PLC O BANK REFERENCE requested O Yes O NO, explain y: Response: Authorized Signer Name: Profession: Corporate Title: Physical (Home) Address: Personal Mailing Address: / i Social Security Number. Date Of Birth: / Place Of Birth: Citizen Of / Home Telephone Number Business Telephone Numbey Business Fax Number. Mobile Number. Email Address: Yews ri Occupation: Photo Identification Type & Number Identification Expiration Date: / O OFAC CHEXSYSTEMS called 0,Yes M No, explain why: SSN Response: Year/ State: ID Response: OPLC • BANK REFERENCE requested • Yes • No, explain why. Response: / Authorized Signer Name: Profession: Corporate Title: Physical (Home) Address: Personal Mailing Address: Social Security tarn . Date Of Birth: Place Of Birth: Citizen Of: Home Telephone umber: Business Telephone Number Business Fax Number. Mobile Number Email Address: Years in Photo Identification Type & Number. Identification Expiration Date: 0 OF LJ CHEXSYSTEMS called • Yes O No. explain why: 9 Lc __.•_•__•._.• • SSN Response: Year: BANK REFERENCE reqCON Response: State: r rum TIAL : ID Response: SONY _GM_00013717 _. rirstbanKFKUUUMU EFTA_00I 24360 EFTA01269527  Validate Business Entity Results Page I of I Validate Business Entity_Results for FSF, LLC RESULTS SUMMARY OFAC CHECK: PASSED ID CHECK: OVERRIDE EN: FAILED Input EIN: NAME MATCH: PASSED Input Name: FSF, LLC ADDRESS MATCH: FAILED Input Address: 6100 Red Hook Ste B3 St. Thomas VI 00802 Dif. Info: E 707 224TH ST BRONX NY 10466 Dif. Info: RIDGELAND MS 39110 Dlr. Info: E 418 MAIN ST CHARLESTON AR 72933 Alternative Verifications -- ---------- PHONE MATCH: PLEASE VERIFY Input Phone: Dif. Info: DI?. Info: Dif. Info: Additional Actions taken: * Note - Please confirm the EIN. j Override Comments: On 10/31/08 at 02:29:07 Janice Stridiron Added: Cleared - Other (type in reason) Letter from the IRS verifying their Tax Id * on file. ,Cleared - Obvious Address Mismatch Business had previous address prior; before using their current address. Account Status: OPENED print This Pegg - Close https://production.penleyinc.ctp kyrkiri CONFIDENTIAL titN iltAct=print&oisi3ofmati363 8 FirstBankPRO00881 EFTA 00121361 EFTA01269528  ID Verification Results Page I of I ID Verification Results for Jeffrey Epstein RESULT