EFTA01654856.pdf

Filing Information Type of Report Initial Report Joint Report Filing Date 03/11/2020 Received Date 03/11/2020 Entry Date 03/12/2020 Submission Method Electronic batch filing Subject Information Subj•ct . 2: :•'GE•S8N Role Subject Subject Type Both Purchaser and Payee Individual/Organization Individual Last(or Entity) Name BORGERSON First Name SCOTT Middle Name G Gender Type Male Date of Birth SSN/ITIN Address(es) Address Type Subject permanent/mailing address Street Address City I I State MA MA - Enhanced ZIP Code Country US US - Enhanced Phone Number(s) Phone Number 1 of 2 Type Mobile Number Phone Number 2 of 2 Type Residence Number I Email(s) Dana 1 EFTA01654856 Subject Information Occupation/Type of Business CEO of Cargo Metrics Corroborative Statement to No Filer Relationship to Reporting Institution TIN Institution(s) Relationship of Subject Customer. Yes Relationship to Financial Institution TIN Institution(s) Relationship of Subject Customer. Yes Affected Account(s) Account 1 of 2 Account Number Financial Institution TIN Account 2 of 2 Account Number Financial Institution TIN • • • XWELL Role Subject Subject Type Both Purchaser and Payee Individual/Organization Individual Last(or Entity) Name MAXWELL First Name GHISLAINE Gender Type Female Date of Birth SSN/ITIN Address(es) Address Type Subject permanent/mailing address Street Address City State MA MA - Enhanced ZIP Code Country US US - Enhanced Phone Number(s) Phone Number 1 of 2 Type Mobile EFTA01654857  Subject Information Number Phone Number 2 of 2 Type Mobile Number Email(s) Occupation/Type of Business Executive Management Corroborative Statement to No Filer Relationship to Reporting Institution TIN Institution(s) Relationship of Subject Customer. Yes Relationship to Financial Institution TIN Institution(s) Relationship of Subject Customer. Yes Affected Account(s) Account 1 of 2 Account Number Financial Institution TIN Account 2 of 2 Account Number Financial Institution TIN Suspicious Activity Information Amount Involved $1,906,662 Date or Date Range of Activity 02/18/2016 - 10/17/2019 Money laundering Other. Suspicion concerning the use of funds: Suspicious EFT/wire transfers Suspicious concerning the source of funds Suspicious use of third-party transactors (straw-man) Transaction out of pattern for customer(s) Other suspicious activities Human trafficking Financial product Deposit account Credit card Financial instrument or Funds transfer payment mechanism Activity Location Financial Institution Location 1 of 2 No Branch Activity Involved Yes Type of Financial Institution Depository institution Primary Regulator OCC EFTA01654858  Activity Location RSSD Number I Legal Name EIN I Role in Transaction Selling/Paying Location Address Address Type Address where transaction occurred Street Address Enhanced City Enhanced State Enhanced ZIP Code Enhanced Country US US - Enhanced Financial Institution Location 2 of 2 No Branch Activity Involved Yes Type of Financial Institution Depository institution Primary Regulator FDIC RSSD Number Legal Name EIN Role in Transaction Selling Location Address Address Type Address where transaction occurred Street Address Enhanced City Enhanced State Enhanced ZIP Code Enhanced Country US US - Enhanced Filer Information Primary Regulator I OCC EFTA01654859  Filer Information Filer Name EIN Address Address Type Reporting party address Street Address Enhanced City hanced State Enhanced ZIP Code Enhanced Country Enhanced Type of Financial Institution Depository institution RSSD Number Contact for Assistance Full Name Phone Number Phone Type Work Law Enforcement Information Law Enforcement Agencies Agency Name FBI New York Office Contacted Law Enforcement Contact(s) Full Name Phone Number Phone Type Work Contact Date 03/02/2020 Narrative CASE ID: C2002421770 DISCOVERY DATE: 02/11/20 ADVISORY HUMAN TRAFFICKING THIS SAR IS BEING FILED JOINTLY ON BEHALF O BASED ON SUSPICIOUS ACCOUNT ACTIVITY AGGREGATING $1,906,661.94. BETWEEN 02/18/15 AND 10/17/19, SUSPICIOUS ACH FUNDS TRANSFERS, WIRE ACTIVITY, AND USB CREDIT CARD PAYMENTS WERE CONDUCTED WITHIN THE FSB ANDEACCOUNTS HELD BY SCOTT G. BORGERSON AND GHISLAINE MAXWELL. DUE TO ASSOCIATION BETWEEN MRS. MAXWELL AND MR. EPSTEIN, THE SUSPICIOUS NATURE OF HER ABRUPTLY ABANDONING HER PROJECT AFTER HIS ARREST, DUE TO THE UNKNOWN SOURCE OF FUNDS, FROM OUTSIDE SOURCES, ITS UNABLE TO BE DETERMINED IF THE ACTIVITY MAY BE ASSOCIATED WITH JEFFERY EPSTEIN AS WELL AS THE, EFTA01654860  Narrative THE UNKNOWN PURPOSE OF THE RENTAL PROPERTIES AND THE SCOPE OF JEFFREY EPSTEIN'S WEALTH, INFLUENCE AND EPSTEIN'S ABILITY TO SOURCE AND MOVE FUNDS TO SUPPORT HIS ALLEGED SEX TRAFFICKING APPARATUS, BELIEVES THE ACTIVITIES ARE SUSPICIOUS. THE-PERTAINS TO $1,571,009.92. THEMSAR PERTAINS TO $335,652.02. MR. BORGENSON IS 44 YEARS OLD, A 23-YEAR CUSTOMER AND CURRENTLY RESIDES IN MANCHESTER, MASSACHUSETTS. INTERNAL RECORDS INDICATE THAT HE IS IN EXECUTIVE MANAGEMENT POSITION, AND A SOCIAL MEDIA PRESENCE INDICATED HE IS THE CEO OF CARGO METRICS TECHNOLOGIES, A DATA SCIENCES COMPANY WORTH OVER $100M WHICH WAS CORROBORATED BY EXTERNAL RESEARCH. MR. BORGERSON CURRENTLY MAINTAINSaHECKING AND SAVINGS ACCOUNTSMICREDIT CARD ACCOUNT, PROPERTY AND CASUALTY (P&C) POLICY, ANC=LIFE COMPANY PRODUCTS DID NOT IDENTIFY ANY NEGATIVE NEWS OR CRIMINAL HISTORY ON MR. BORGENSON. MRS. MAXWELL IS 58 YEARS OLD, IS A THREE-YEARMICUSTOMER AND CURRENTLY RESIDES IN MANCHESTER, MASSACHUSETTS. INTERNAL RECORDS INDICATE SHE IS IN AN EXECUTIVE MANAGEMENT POSITION AND EMPLOYED BY TERRAMAR, AN OCEAN CONSERVATION CHARITY INCORPORATED IN 2013 BY MRS. MAXWELL IN SALISBURY, UNITED KINGDOM. MRS. MAXWELL CURRENTLY MAINTAINS CHECKING ACCOUNT, ■ CREDIT CARD ACCOUNT, AND A P&C POLICY. MRS. MAXWELL REPORTED HER ANNUAL INCOME AS $250,000.00 TO $499,999.00 WITH A NET WORTH OF $1,000,000.00. EXTERNAL RESEARCH REVEALED THAT IN 2012, MRS. MAXWELL FOUNDED THE TERRAMAR PROJECT, AN ENVIRONMENTALIST NONPROFIT ORGANIZATION WITH A FOCUS ON OCEAN PROTECTION THAT WAS ABRUPTLY ABANDONED BY MRS. MAXWELL DAYS AFTER HER ASSOCIATE JEFFREY EPSTEIN WAS ARRESTED ON SEX TRAFFICKING CHARGES. ADDITIONALLY, THERE ARE NUMEROUS ALLEGATIONS, DUE TO HER TIES TO JEFFERY EPSTEIN, THAT SHE MAY HAVE PROCURED AND SEXUALLY TRAFFICKED UNDERAGE GIRLS FOR JEFFERY EPSTEIN AND OTHERS. ON 02/11/20, 'ONDUCTED A REVIEW OF ALL ACCOUNTS HELD BY MR. BORGENSON AND MRS. MAXWELL FOR THE PERIOD OF 02/04/15 TO 02/04/20. IDENTIFIED SUSPICIOUS ACTIVITY WITHIN CHECKING ACCOUNT AN' CREDIT CARD ACCOUN ON 04/15/12M CREDIT CARD ACCOUNT HELD BY MR. BORGENSON AND MRS. MAXWELL WAS ESTABLISHED. ON 04/16/12, HECKING ACCOUNT HELD BY MR. BORGENSON AND MRS. MAXWELL WAS ESTABLISHED. BETWEEN 02/18/15 AND 10/12/19, 95 ACH FUNDS TRANSFERS TOTALING $602,000.00 CREDITED CHECKING ACCOUNTS, RANGING FROM $1,000.00 TO $20,000.00. THE ORIGINATOR, SCOTT G. BORGERSON, UTILIZED EXTERNAL ACCOUNT aT CITIZENS BANK N.A., AS THE DEBITED EFTA01654861  Narrative PARTY. THIS ACTIVITY WAS DEEMED SUSPICIOUS DUE TO THE UNKNOWN SOURCE OF THE FUNDS FROM THE EXTERNAL ACCOUNT. BETWEEN 03/05/15 AND 06/01/18, 48 ACH FUNDS TRANSFERS TOTALING $208575.00 DEBITED FSB CHECKING ACCOUNT RANGING FROM $1,625.00 TO $7,300.00. THE BENEFICIARIES OF THE ACH FUND TRANSFERS ARE SHELVING ROCK TRUST, UTILIZING EXTERNAL ACCOUNT AT SANTANDER BANK, LOCATED IN PENNSYLVANIA. DIANA CHEN, UTILIZING EXTERNAL ACCOUNT -AT EAST WEST BANK, LOCATED IN CALIFORNIA AND SCOTT BORGERSON, UTILIZING ACCOUNT NUMBER AT WELLS FARGO BANK. EXTERNAL RESEARCH IDENTIFIED SHELVING ROCK AS A PURCHASER AND SPECIALTY ASSET MANAGEMENT FIRM. INTERNAL RECORDS SHOW THE SHELVING ROCK TRUST ACCOUNT IS LINKED TO THE CUSTOMER'S PROFILE AND SUBTITLED "RED COTTAGE RENT'. ADDITIONALLY, DIANA CHEN'S LINKED ACCOUNT IS SUBTITLED AS "36 BEACON RENT 7100 PMONTH". THE TRANSFERS ARE PRIMARILY FUNDED BY THE ACH TRANSFERS FROM MR. BORGERSON'S EXTERNAL ACCOUNT HELD AT CITIZENS BANK N.A. EXTERNAL RESEARCH SHOWS BOTH MR. BORGENSON AND MS. CHEN PREVIOUSLY RESIDED AT "36 BEACON ST, BOSTON, MA" WHICH CURRENTLY RENTS FOR $7,500 PER MONTH. THESE PAYMENTS WERE DEEMED SUSPICIOUS DUE TO THE UNKNOWN PURPOSE OF THE RENTAL PROPERTY. USAA AMLI DID NOT IDENTIFY ANY NEGATIVE NEWS OR CRIMINAL HISTORY ON SHELVING ROCK TRUST OR DIANA CHEN. BETWEEN 05/26/15 AND 10/17/19, 48 USB CREDIT CARD PAYMENTS TOTALING $335,652.02 DEBITED USAA FSB CHECKING ACCOUNT 140723668, RANGING FROM $2.12 TO $22,307.24. THE CREDIT CARD PAYMENTS WERE APPLIED TO USB CREDIT CARD ACCOUNT 4270826003905034 AND WERE FUNDED BY TRANSFERS FROM THE CUSTOMER'S EXTERNAL ACCOUNT AT CITIZEN'S BANK N.A WHEREAS THE ULTIMATE SOURCE OF FUNDS IS UNKNOWN. THIS AMOUNT WILL BE COUNTED TWICE DUE TO FUNDS CROSSING TO DISTINCT LINES OF BUSINESS. BETWEEN 01/03/17 AND 07/01/19, 11 INCOMING WIRES TOTALING $424,782.90 CREDITED USAA FSB CHECKING ACCOUNT 140723668, RANGING FROM $1,581.66 TO $62,726.14. THE INCOMING WIRES ORIGINATE FROM ANGARA TRUST VIA NUTTER MCCLENNEN & FISH LLP, UTILIZING EXTERNAL ACCOUNT Y1 36510 AT UBS AG AND MONTPELIER TRUST VIA NUTTER MCCLENNEN & FISH LLP, UTILIZING EXTERNAL ACCOUNT Y1 45614 AT UBS AG, AS THE DEBITED PARTY, WITH NO ASSOCIATED MEMOS. ONLINE RESEARCH SHOWS ANGARA LLC TO BE A DOMESTIC LIMITED LIABILITY COMPANY FORMED IN 2016 IN WHICH RECORDS WERE MAINTAINED C/O NUTTER MCCLENNEN & FISH LLP. ADDITIONALLY, THERE IS A PUBLISHED ARTICLE THAT IDENTIFIES ANGARA LLC AS A TRUST FORMED IN 2016 BY MRS. MAXWELL'S SISTER, CHRISTINE MAXWELL AND MR. BORGENSON. THE COMPANY WAS DISSOLVED ON 01/02/18. ALTHOUGH ONLINE RESEARCH RESULTS ARE INCONCLUSIVE, MONTPELIER TRUST APPEARS TO BE AN ACCOUNT WHOSE PURPOSE IS TO EFTA01654862  Narrative PRESERVE, CONSTRUCT AND/OR REHABILITATE AFFORDABLE HOUSING UNITS. THE ACTIVITY WAS DEEMED SUSPICIOUS DUE TO THE SCOPE OF JEFFREY EPSTEIN'S WEALTH, INFLUENCE AND EPSTEIN'S ABILITY TO SOURCE AND MOVE FUNDS TO SUPPORT HIS ALLEGED SEX TRAFFICKING APPARATUS. USAA AMLI DID NOT IDENTIFY NEGATIVE NEWS OR CRIMINAL HISTORY FOR ANGARA TRUST, MONTPELIER TRUST OR NUTTER MCCLENNEN & FISH LLP ADDITIONAL ACTIVITY WITHIN THE CUSTOMERS' ACCOUNT CONSIST OF BILL PAYMENTS, PHONE PAYMENTS, AND AMERICAN EXPRESS CREDIT CARD PAYMENTS WHICH APPEARS TO BE NORMAL CONSUMER RELATED BEHAVIOR. USAA AMLI DID NOT IDENTIFY SUSPICIOUS ACTIVITY WITHIN THE CUSTOMER'S OTHER USAA ACCOUNTS. USAA AMLI BELIEVES THE ACTIVITIES ARE SUSPICIOUS AS THE CUSTOMERS RECEIVED FUNDS TRANSFERS INTO THEIR USAA FSB CHECKING ACCOUNT FROM A RELATED EXTERNAL ACCOUNT AND INCOMING WIRE TRANSFERS FROM ANGARA TRUST AND MONTPELIER TRUST VIA NUTTER MCCLENNEN & FISH LLP. ONLINE RESEARCH SHOWS ANGARA LLC WAS FORMED BY MRS. MAXWELL'S SISTER, CHRISTINE MAXWELL AND MR. BORGENSON. NO CONCLUSIVE INFORMATION WAS LOCATED FOR THE MONTPELIER TRUST. THE FUNDS EXITED THE ACCOUNT VIA USB CREDIT CARD PAYMENTS AND ACH TRANSFERS TO THE BENEFIT OF THE SHELVING ROCK AND DIANA CHEN, WHOSE ACCOUNTS ARE LINKED TO OUR CUSTOMERS PROFILE. THE PURPOSE OF THE TRANSACTIONS APPEARS TO BE RENTAL PROPERTY PAYMENTS. ALTHOUGH MR. BORGERSON IS THE CEO OF A TECH COMPANY WORTH MILLIONS OF DOLLARS AND MRS. MAXWELL'S ANNUAL INCOME OF $250,000.00 TO $499,999.00 WITH A NET WORTH OF $1,000,000.00 IS ENOUGH TO SUBSTANTIATE THE FUNDS TRANSFERS, THE OVERALL ACTIVITY IS DEEMED SUSPICIOUS DUE TO THE UNKNOWN PURPOSE OF THE RENTAL PROPERTIES, THE ASSOCIATION AND ALLEGATIONS FOUND FOR MRS. MAXWELL TOWARDS HER POTENTIALINVOLVEMENT TO PROCURE SEX TRAFFICKING VICTIMS AND THE SCOPE OF JEFFREY EPSTEIN'S WEALTH, INFLUENCE AND EPSTEIN'S ABILITY TO SOURCE AND MOVE FUNDS TO SUPPORT HIS ALLEGED SEX TRAFFICKING APPARATUS. TO DATE, THE USAA FSB CHECKING ACCOUNT AND USB CREDIT CARD REMAIN OPEN PENDING FURTHER INVESTIGATION. SUPPORTING DOCUMENTATION WILL BE PROVIDED TO LAW ENFORCEMENT UPON REQUEST. FOR ASSISTANCE, CONTACT INFORMATION SHARING TEAM WITH USAA AMLI AT 1-210-498-8970 OR LAWENFORCEMENTTEAM@USAA.COM EFTA01654863