EFTA01594357.pdf

Ticket#: 102238348 Client Name: ECI#: LOB: POT AND KETTLE 0033839248 PB Account#: Account Title: Account Type: Initiated Date#: Initiator: Initiating Team: 08/22/2011 10:43 AM DEBRA WHITE PB FRONT OFFICE Verify and Confirm for POT AND KETTLE Final Risk Rating Initial Risk Rating GCS Report Requested Presence of Potential High Risk Indicators Reason for Adjustment Moderate Standard Full No Derogatory information. GCS Grid Search Type Security Service Details Company Information Corporate Records Other Database Searches (RDC/MIS/Factiva) Internal Database Search (CSSS/FPS) Information not confirmed on Pot and Kettle for tax id and address. Internal database search revealed prior GSI research and the following derogatory information was reported: Several newspaper articles detailing the investigation conducted by Britains Serious Fraud Office against Robert Maxwell. He allegedly used pension funds to service debts, cover operating losses, gamble in the foreign exchange markets, and support the stock of his publicly held companies. The agency is also looking into a complaint from Swiss Bank Corp., which says it did not receive collateral for a $100 million loan to a small private Maxwell company. Newspaper article dated 12/01/2000, which stated that Ghislaine Maxwells source of wealth is being classified as something of a mystery. Newspaper article dated 08/09/1996 detailing the arrest of EFTA01594357 Ghislaine Maxwell on DWI charges. Numerous newspaper articles detailing the criminal fraud charges brought against Kevin and Ian Maxwell (sons of Robert Maxwell). Newspaper article dated 6/23/2005 detailing Robert Maxwell misappropriated funds from the companies under his control. According to the newspaper article, "He pledged assets as security for additional loans", but instead of delivering the assets to the lender, he would simply sell the assets for cash. "For example, Berlitz language school was supposedly sold to a Japanese publishing company, but the shares had previously been pledged as security for loans from Swiss Volksbank and Lehman Brothers." State Court Searches Federal Court Searches Personal Particulars Publications Regulatory Sanctions OFAC/Control List Search Negative or Inconsistent Information No records were found. Information confirmed; details included in the attachment. Information confirmed; details included in the attachment. Information confirmed; details included in the attachment. No records were found. A search of OFAC revealed no matches. No No No No No No Yes Further Review Required Yes Information not confirmed on Pot and Kettle for state of domicile. Yes No records were found. No Yes EFTA01594358 GCS Red Dot Has this been identified as Red Dot KYC? Negative Information Found No Yes Banker Attestation Details As the client sponsor, I understand that I am primarily responsible for protecting the firm's reputation from inappropriate business relationships, as well as from fraud and money laundering. By approving this KYC, I am sponsoring this client as to their character and reputation and from a legal/regulatory standpoint. Please state your rationale for conducting business with this client Please respond to any issue(s) identified in the GS&I grid that either needs further review, or red dot which is not already covered in a Business Case within this KYC Comments Yes Long-term clientsopening up additional accounts. reviewed Primary Information Client Type Client Status Confidential Name? Legal Business Name Country of Primary Domicile Primary Country of Assets Country of Organization Industry Code (NAIC) Client Legal Entity Type Date of Incorporation/Situs (Date of Trust) Documentary Evidence What is the nature/purpose of this entity? High Risk Jurisdiction Non Individual Client No POT AND KETTLE UNITED STATES UNITED STATES UNITED STATES ALL OTHER MISC CHEM PRODUCT AND PREP MFG [325998] Limited Liability Company 12/21/2009 LLC - State Certificate The client owns a patent for a hand cleaning product/device. The client is looking to buy a company that holds patents for anti microbial technology. EFTA01594359 No Is the entity a Personal Holding Company (PHC) or Personal Investment Company (PIC) located in an offshore jurisdiction? No Front Office Restricted? Active Indicator Insider Code (Reg. 0) Primary Domicile State WebSite Organization State Secondary Industry Code (NAIC) Client Category Profit Delaware Normal Delaware Address(es) Type Legal Notes Address City, State, Postal Code MIAMI BEACH, Florida, 33139 Country Tools UNITED STATES Map it Entered by BATCH Date of Update Preferred 08/19/2011 Yes EFTA01594360 Phone(s)/Fax(s) Type Work Notes Phone Number Tools Verify "Do Not Call" List Entered by SYSTEM Date of Update 08/19/2011 Preferred Yes Email(s) Type Email address not available Notes Email Entered by Date of Update Preferred Cost Center & Hierarchy Client Status Client Client Sponsor Cost Center Client Service Team GIO Trust Advisor Decision Maker DM ECI PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 Ian E Hirschfield GHISLAINE MAXWELL 0106585908 Client Type New or Existing Client Entity Type Portfolio Manger Investor Non Individual Existing Entity Identification Withholding Federal Status Domestic Certified Withholding SSN/TIN Certification Date SSN/TIN/EIN EFTA01594361 08/22/2011 Introduction & Wealth Introduction Type Net Worth of client($) Existing JPMorgan Client - Inside LOB 30,000,000 00 ECI Additional Party Information Party Type 0106585908 Individual Party Name Ghislaine Maxwell Last Completed Search Date 03/31/2005 KYC Status Completed Report Type Full Relation Type Owner Powers Percent Owned 100.00 EFTA01594362 Primary Information for Ghislaine Maxwell Client Type Client Status Front Office Restricted? Confidential Name? Country of Primary Domicile Prefix/Title First Name Middle Name Last Name Suffix Previous Name/MMN/Alias Citizenship Employer Name Occupation Years at Occupation Individual Client Normal No UNITED STATES Ghislaine Maxwell UNITED STATES High Risk Jurisdiction Industry Code (NAIC) Secondary Industry Code (NAIC) Insider Code (Reg. 0) Full Name Gender Date of Birth Primary Country of Assets 01/01/1901 UNITED STATES Ghislaine Maxwell Generation Active Indicator Marital Status Yes Address(es) Type Legal Notes Address City, State, Postal Code MIAMI BEACH, Florida, 331391331 Country EFTA01594363 Tools UNITED STATES Map it Entered by SYSTEM Date of Update Preferred 03/22/2011 Yes Phone(s)/Fax(s) Type Home Notes Phone Number Tools Verify "Do Not Call" List Entered by SYSTEM Date of Update 03/22/2011 Preferred Yes Email(s) Type Home Notes Email Entered by SYSTEM Date of Update 03/22/2011 Preferred Yes Cost Center & Hierarchy Client Status Client Client Sponsor Cost Center Client Service Team PAUL V MORRIS 008634 - CHBG CHBG (DE) 4 Entity Type Decision Maker Client Type Individual EFTA01594364 Identification Withholding Federal Status Introduction & Wealth Introduction Type Net Worth of client($) Introduction Non Individual Entity Type For Profit? Locations Served? Are beneficial owners/principal shareholders associated with this business? Who owns this entity? Please Provide ownership details Limited Liability Company - For Profit Yes Domestic Yes Individual Ghislaine Maxwell is the sole owner of the entity details below: Ghislaine Maxwell DOB: SSN: Govt. ID: Florida D/L # Ownership is not equal to 100%? Are there any authorized signers or any other individuals with authority over the entity? What independent background check, in addition to the Global Corporate Security ("GCS") background check, has been carried out? Check all that apply and provide the date in which the background check was conducted. (at least 1 must be selected) JPMC Network Date JPMC Network Comments No No JPMC Network 08/22/2011 This is another part of an existing client relationship with Ghislaine Maxwell. Ghislaine Maxwell is the daughter of the late Robert Maxwell who was a British media proprietor and former Member of Parliament. Ghislaine Maxwell was educated at Marborough College and Balliol College, Oxford. Ghislaine Maxwell is an entrepeuner/business owner Politically Exposed Person Are any of the beneficial owners/authorized signers or other individuals with authority over this entity a current or former Senior United States or Non-USA Political Official / also known as a Politically Exposed Person (PEP) or related to one? No Source of Wealth/Financial Information EFTA01594365 Client Category(for SOW) Source of Wealth- identify the clients source of wealth from the following list of options Provide detailed and specific information. Which country(ies) is(are) the Client's primary Source of Wealth or Income derived? For Profit Other Ghislaine Maxwell is the daughter of the late Robert Maxwell who was a British media proprietor and former Member of Parliament. Ghislaine Maxwell was educated at Marborough College and Balliol College, Oxford. Ghislaine Maxwell is an entrepreuner/business owner UNITED STATES EFTA01594366 Is this an Operating Company? Total Net Worth $ No 30000000.00 What was the total net worth based on? Is this client a Professional Service Provider acting as a financial intermediary (Gatekeeper/Financial Liaison), with assets held on behalf of one or more unidentified underlying clients unknown to the bank? Is this entity a Private Equity Fund (Venture Capital Fund or Leveraged Buyout)? Is this a Hedge Fund? (Pooled investment vehicles (often partnerships) that primarily invest financial capital of third party investors in enterprises that are too risky for the standard capital markets or bank loans.) Is this a Cash Intensive business? (Cash-intensive businesses/entities exist in various industry sectors and include, but are not limited to convenience stores, grocery stores, restaurants, bars, retail stores, liquor stores, cigarette distributors, privately owned ATMs, vending machine operators and parking garage operators.) Is this entity any of the following business types? Is the Entity a Personal Holding Company (PHC) or Personal Investment Company (PIC) located in an offshore jurisdiction? Financial Statements No No No No aa. None of the above No Business Case Please specify why you are comfortable with this client given the identified risk factor(s). Your answer is your "business case" and should detail all mitigating factors. Provide client history/detail, including when the relationship was established, how it came to be in PB/PWM, client's association with other JPM LOBS, etc. Client known to whom (JPMorgan employees), how well, and how long: Overall PB/PWM relationship size and type of accounts: Is this a shared client, what other LOB has a relationship with the client? Provide relationship manager name (if known), client of other LOB since (date), and relationship size? Additional Comments Long-term client of the Private bank. Copnsolidating assets with JP Morgan. EFTA01594367 Long-term relationship with PB. (.10 years) Senior management of PB .$10 million no N/A Expected Activity Deposit Account(s) Transaction Types Cash Deposits Cash Withdrawals Check Deposits Checks Paid Incoming Wires (Domestic) Outgoing Wires (Domestic) Incoming Wires (International) Outgoing Wires (International) ACH Deposits ACH Payments Internal Transfer (Debits/Credits) Asset Purchases/Sales What is the initial/ongoing source of funding for the client's Deposit Account(s) ? The initial funding will be $110,000 and will be from an internal transfer from the client's savings account. The ongoing source of funding will be from the sale of the anit microbial hand cleaning product/device to various clients. Expected Activity Levels Low (1-10) Low (1-10) Low (1-10) Low (1-10) Anticipated Dollar Amount Totals per Month $10,000 TO $50,000 $10,000 TO $50,000 $10,000 TO $50,000 $10,000 TO $50,000 EFTA01594368 What is the purposed/intended use of account(s)? Please provide a detailed description of how the Deposit Account(s) will be used by the client. Sales/purchases of the anti microbial hand cleaning product/device from clients will be deposited into checking account. The purpose of the checking account will be to pay everyday living expenses and monthly bills for the client. Additional Client Information Please include any additional information that would further explain your knowledge of the client (family tree/history, public information, websites, etc.) Approval History Stage Name Banker Attestation Market Manager Approval Regional Director Approval DF#@&T15#7@1 Signoff Date 12/05/2011 10:32 AM 12/19/2011 2:30 PM 12/20/2011 4:25 PM Owner SID Owner Name PAUL V MORRIS WILLIAM M SHERIDAN WILLIAM M SHERIDAN EFTA01594369