EFTA00151545.pdf

FinCEN I Financial Crimes Enforcement Network Vaal Saes Damara d she Trasury 0919 L4091000 LE AISEI 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 Surjectl •f3:E'STEIN 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 Passport Identification Number Issuing Country Code US Address(es) Address Type Subject permanent/mailing address Street Address City State ZIP Code Country 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 I Page 1 The enclosed reformation was collected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury regOations implementing the BSA. See 31 U.S.C. 5311, et seq.: 31 CFR Chapter X. The reformation a sensitive ti nature and is to be heated accadingly. The information may be used only for a purpose con ustent with a crtnnal. tax. or regulatory nveztigation or proceeding. or in the conduct of ntelligence or counterntelligence activities. inclueng 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 Palencia Crates Enforcement Network or 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 aiminal or civil sanctions. EFTA00151545  FinCEN Financial Crimes Enforcement Network United Stan ()Tasman d the ricauty 09Z9 L4091000 IC VS9 BSAR Transcript BSA: 310001 50416250 and DCN: Subject Information Institution(s) Relationship of Subject Customer. Yes Affected Account(s) Account Number Financial Institution TIN Subject 2 of 3 KAHN Role Subject Subject Type Purchaser/Sender Indiyidual/Organizati Last(or Entity) First Gender Type Male D Form(s) of Identification Identification Type Passport Identification Num . Issuing Country Code US Address(es) Address 1 of 3 Address Ty Street Addres C. NEW YORK - Enhanced State NY NY Enhanced ZIP Code 10021-3241 10021-3241 - Enhanced Country US US - Enhanced Address 2 of 3 Address Ty Street Addres Cit NEW YORK - Enhanced State NY NY - Enhanced ZIP Code 10022-6146 10010-5516 - Enhanced Page 2 The enclosed mformation was caected and disseminated under provisions of the Bank Secrecy Act (the 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 mformation a sensitive m nature and is to be treated accadingly The information may be used only fa a purpose consistent with a crrnmat. tax. or regulatory mvestigation or proceeding. or in the conduct of mtelligence or countermtelligence activities. incluckw analysis, to protect against mtemational terrorism. See 31 U. S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Financial Crimes 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 passtle criminal activity. akin to confidential informant tips. Unauthorized release of information collected wider the BSA may result in criminal or civil sanctions. EFTA00151546  FinCEN I Financial Crimes Enforcement Network United Sages Document of the Imousy 09Z9 LPN L000 LE .VSO Subject Informal' Phone Nu Occupation/Type of B Relationship to Fi Instit Affected Acc Subject 3 of 3 : SOUTE Role Subject Subje Individual/Orgar Last(or Entity Form(s) of Identil Page 3 The enclosed reformation was caected and disseminated under provisions 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 reformation a sensitive ri nature and is to be treats accordingly. The information may be used only fa a purpose con ustent with acrmnal, tax. or regulatory nvestigation OC proceeding. Of in the conduct of ntelligence a counterntelligence activities. includeg analysis. to protect against nternabonal terrorism. See 31 U.S.C. 5311. The information camel be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Friancial Cranes Enforcement Netwakor 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 confidential informant tips. Unauthorized release of information collected wider the BSA may result in criminal or civil :miens:. EFTA00151547  FinCEN I Financial Crimes Enforcement Network United Sean Depettntent of the Ticanuty 0919O,091.000ICAIS9 BSAR Transcript BSA: 310001 50416250 and DCN: Subject Information Issuing Country Code VI Address(es) Address Type Subject permanent/mailing address Street Address City State ZIP Code 008021348 00802-1348 - Enhanced Country 0 NAICS Code 5221 NAICS Code Text Depository Credit Intermediation Phone Number(s) Type Work Number Relationship to Financial Institution TIN Institution(s) Relationship of Subject Customer. Yes Affected Account(s) Account Number Financial Institution TIN 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 Locatior 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 Legal Name Charles Schwab & Co., Inc EIN Address Address Type I Address where transaction occurred Page 4 The enclosed riformatico was caected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury reguLstions implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The riformetion is sensitive m nature and is to be treats acccodingly. The information may be used only for a purpose con ustent with acrmna tax. or regulatory owestigation or proceeding. or in the conduct of intelligence or countermtelligence activities. inclutran 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 Potential Crones Enforcement Netwarkor his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passable criminal activity. akin to ccofidential informant tips. Unauthorized release of information collected wider the BSA may recult in criminal or civil smiths:. EFTA00151548  FinCEN Financial Crimes Enforcement Network united Sums Department of the ricbuty 0919O,09L00MAIS9 BSAR Transcript BSA: 310001 50416250 and DCN: Activity Location Street Address Internal Control File Number CA111517 Filer Informati Primary Type of Financial RSS Internal control/f ContactforI Law Enforcem No Law Enforcement information Ayaliame Page The enclosed reformation was colected and disseminated under provisions of the Bank Secrecy Acl (the SSA) and U.S. Department of the Treasury regdations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chapter X. The reformation is senative ti nature and is to be treats accadingty. The information may be used only fa a purpose con ustent with acr.nnd. tax. or regulatory nvestigation or proceeding. or in the conduct of intelligence or counterntelligence activities. incluctIg analysis, to protect against nternational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. di:closed. or transmitted without snot approval of the Director of Frnancial Crones Enforcement Netwakor his authorized delegate. Suspicious activity reports filed under the GSA must be treated with particular care given that they contain unsubstantiated allegations of pas:tale criminal activity. akin to ccondentml informant tips. Unauthorized release of information collected wider the BSA may result in aimind or civil 'webs:. EFTA00151549  Financial Crimes Enforcement Network FinCEN I UMW Scats Deptmalt of the Treasury 09Z9 1.17051.000 IC :VS9 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, . The company is registered in the United States (U.S.) Virgin Islands, license number 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. (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. 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 registered to Southern Trust Company, Inc. 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 Chapter 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 criminal. tax. or regulatory nvestigation or proceeding. or in the conduct of ntelligence or counterntelligence activities. induct-5g analysis, to protect against ntemational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without pith 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. EFTA00151550  -n Fi CEN Financial Crimes Enforcement Network United Saws Depstmcne ti the Trasury O9 9117091000 le :VS9 BSAR Transcript BSA: 31000150416250 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 and Jeffrey Epstein, from brokerage account . 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 Pach =in Morocco. The funds were sent to an account at Bank Julius Baer and Co. Ltd. located in Zurich Switzerland, account numbel 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 S asking if it was possible to terminate the aforementioned wire. The Schwab representative asked the reason for the reversal request, and 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 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 CFRChapter X. The eformation is sensitive a nature and is to be treated accordingly. The information may be used only for a purpose con3stent with a crew's{ tax. or regulatory swestigation or proceeding. or in the conduct of ntelligence or counterntelligence activities. inclueng analysis, to protect against nternational terrorism. See 31 U.S.C. 6311. The information cannot be further released. disseminated. disclosed. or transmitted without Ow approval ol the Director of Ferancial 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 conklenbal informant tips_ Unauthorized release ol information collected under the BSA may result in criminal or civil sanctions. EFTA00151551  Financial Crimes Enforcement Network Fi-I nCEN United Saws Depairmaic at the Ttcbuty 09Z9 Ii091.000 IC :VSEI 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, 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 S registered as Southern Trust Company, Inc., on 07/10/2019. 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 and Jeffrey Epstein; the request was to send $14,950,000 USD to Marc Leon located at Imm El Dach it Morocco. 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 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 on 07/10/2019, Schwab made an outbound call to where he confirmed he did not want the $14,950,000.00 wire to be processed. In addition, 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 reformation was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Deportment of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chapter X. The nformation is sensitive al nature and is to be treated accordingly. The information may be used only for a purpose con ustent with a crimes{ tax. or regulatory eve:tit/atm or proceeding. Of in the conduct of ntelligence or counterntelligence activities. include.; analysis, to protect against nternabonal terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without pro; 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 conklenbal informant tips_ Unauthorized release of information collected ruder the BSA may result in criminal or civil sanctions. EFTA00151552  FinCEN I Financial Crimes Enforcement Network uniti suits pepsin...a the liceuty 09Z91.17091.0001.6 :VS£3 BSAR Transcript BSA: 310001 50416250 and DCN: Narrative As of 07/10/2019, there have not been any funds remitted from the three accounts associated to 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 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 received a $2,000,000.00 wire from an external like-registered account to Southern Trust Company. In addition, brokerage account la 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 S 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 nformation was selected 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 Chapter X. The eformation is sensitive n nature and is to be treated accordingly. The information may be used only for a purpose consistent with a setae* tax. or regulatory evestigation or proceeding. Of in the conduct of ntelligence a counterntelligence activitiesoncludeg analysis, to protect against nternabonal terrorism. See 31 U.S.C. 5311. The information carrot be further released. disseminated. dtsclo--ed. or transmitted without pier 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 conklenhal informant tips- Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. EFTA00151553