EFTA00173953.pdf

SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 MEMORANDUM Date: May 18, 2015 To: Assistant Special Agent in Charge Special Operations Division From: Director OCDETF Fusion Center Subject: Target Profile: • Jeffre EPSTEIN• WARNING This product contains sensitive proprietary law enforcement information which may be either classified or the subject of stringent caveats. This product is compiled from multi-agency databases and open sources, and should not be treated as a finished investigative product. OCDETF suggests advising your prosecuting attomey(s) of this intelligence product. The recipient and attomey(s) are advised that this product may not be referenced in affidavits, indictments. extradition documents, other court related documents, press releases. or duplicated as a pan of the discovery process without the express written permission of the OCDETF Fusion Center and the originating agencies. This product is provided to your agency for lead purposes only and may not be disseminated to third panics without approval of the originating agencies. Further. investigative action based upon this information should be coordinated with the contributing agencies. This product should be destroyed in a manner consistent with its classification upon determination that retention is no longer necessary to support an investigation, prosecution or related activity. Date of Request: April 28, 2015 Case File Number / Agency: C1-11-0049 GDEP: YNL3B (DEA) OCDETF Case Number: NY-NYS-0829 OCDETF Operation Name: Chain Reaction Requestor / Agency / Telephone Number: OFC Unit Chief / Telephone Number: OFC Desk Officer / Telephone Number: OFC Intelligence Analyst / Telephone Number: SOD OSF Contact / Telephone Number: Agency information contained herein: ATF SI CBP la DEA O DOC ❑ DOL OIG li DSS OAFP ONCA/SOCA OBOP SDOS 114 FBI 61 ICE ❑ IRSCI O USMS ❑ USPIS ❑ USSS ❑NZP lilF1NCEN FBI Guardian Incident SENSITIVE BUT UNCLASSIFIED EFTA00173953  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 Table of Contents ANALYTICAL FINDINGS 1 Background: 1 • Analytical Findings: 1 TARGET 1— 4 BIOGRAPHICAL/IDENTIFYING DATA 4 ADDRESSES 5 COMMUNICATIONS 5 Telephone Numbers 5 BORDER CROSSINGS 5 Border Crossings - Air S LINKED INVESTIGATIONS 6 CRIMINAL HISTORY/NCIC 6 Offline NC1C 6 FINANCIAL INFORMATION 7 USAR — Unified Suspicious Activity Report(s) 7 ASSETS 7 Financial Accounts) 7 TARGET 2 — 8 BIOGRAPHICAL/IDENTIFYING DATA 8 ADDRESSES 8 COMMUNICATIONS 8 Telephone Numbers 8 BORDER CROSSINGS 8 Border Crossings - Air 8 LINKED INVESTIGATIONS 9 CRIMINAL HISTORY/NCIC 9 Offline NC1C 9 FINANCIAL INFORMATION 10 USAR — Unified Suspicious Activity Report(s) 10 TARGET 3 - 11 BIOGRAPHICAL/IDENTIFYING DATA 1I ADDRESSES II COMMUNICATIONS II Telephone Numbers I Websites, Email Addresses, IP Addresses II BORDER CROSSINGS 12 Border Crossings - Air 12 LINKED INVESTIGATIONS 12 CRIMINAL HISTORY/NCIC 12 Offline NC1C 12 SENSITIVE BUT UNCLASSIFIED EFTA00173954  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 FINANCIAL INFORMATION 13 USAR — Unified Suspicious Activity Report(s) 13 TARGET 4 — JEFFREY EPSTEIN 14 BIOGRAPHICAL/IDENTIFYING DATA 14 ADDRESSES 14 COMMUNICATIONS 15 Telephone Numbers 15 Websites, Email Addresses, IP Addresses 15 BORDER CROSSINGS 15 Border Crossings - Air 15 CORPORATE/BUSINESS AFFILIATIONS 15 LINKED INVESTIGATIONS 16 CRIMINAL HISTORY/NCIC 17 Offline NCIC 17 FINANCIAL INFORMATION 19 USAR — Unified Suspicious Activity Report(s) 19 UC7'R — Unified Currency Transaction Report(s) 19 CTR — Currency Transaction Report(s) 19 AssErs 20 Financial Accounts) 20 FAMILY MEMBER/ASSOCIATE IDENTIFYING INFORMATION 21 Associates 21 TARGET 5 - 22 BIOGRAPHICAL/IDENTIFYING DATA 22 ADDRESSES 22 COMMUNICATIONS 22 Telephone Numbers 22 Websites, Email Addresses, IP Addresses 23 BORDER CROSSINGS 23 Border Crossings - Air 23 LINKED INVESTIGATIONS 23 CRIMINAL HISTORY/NCIC 24 Offline NCIC 24 FINANCIAL INFORMATION 25 USAR — Unified Suspicious Activity Report(s) 25 UC7'R — Unified Currency Transaction Report(s) 25 AssErs 26 Financial Accoum(s) 26 TARGET 6 — 27 BIOGRAPHICAL/IDENTIFYING DATA 27 ADDRESSES 28 COMMUNICATIONS 28 Telephone Numbers 28 SENSITIVE BUT UNCLASSIFIED EFTA00173955  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 Websites, Email Addresses, IP Addresses 28 BORDER CROSSINGS 28 Border Crossings - Air 28 CORPORATE/BUSINESS AFFILIATIONS 29 LINKED INVESTIGATIONS 29 CRIMINAL HISTORY/NCIC 29 Offline NCIC 29 FINANCIAL INFORMATION 30 USAR — Unified Suspicious Activity Report(s) 31 CTR - Currency Transaction Report(s) 31 AssErs 31 Financial Account(s) 31 TARGET 7 - 32 BIOGRAPHICAL/IDENTIFYING DATA 32 ADDRESSES 32 COMMUNICATIONS 32 Telephone Numbers 32 Websites, Email Addresses, IP Addresses 32 LINKED INVESTIGATIONS 33 CRIMINAL HISTORY/NCIC 33 Offline NCIC 33 FINANCIAL INFORMATION 34 USAR — Unified Suspicious Activity Report(s) 34 UCTR — Unified Currency Transaction Report(s) 34 CTR - Currency Transaction Report(s) 35 TARGET 8 — 36 BIOGRAPHICAL/IDENTIFYING DATA 36 ADDRESSES 36 COMMUNICATIONS 36 Telephone Numbers 36 Websites, Email Addresses, IP Addresses 36 BORDER CROSSINGS 37 Border Crossings - Air 37 LINKED INVESTIGATIONS 37 CRIMINAL HISTORY/NCIC 37 Offline NCIC 37 FINANCIAL INFORMATION 38 USAR — Unified Suspicious Activity Report(s) 38 TARGET 9 - 39 BIOGRAPHICAL/IDENTIFYING DATA 39 ADDRESSES 40 COMMUNICATIONS 40 Telephone Numbers 40 SENSITIVE BUT UNCLASSIFIED EFTA00173956  SENSITIVE BUT UNCLASSIFIED OFC-TP-15.12392 SODOFC-15.12392 Date of Report: May IS, 2015 Websites, Email Addresses, IP Addresses 40 LINKED INVESTIGATIONS 40 CRIMINAL HISTORY/NCIC 41 Offline NCIC 41 FINANCIAL INFORMATION 41 USAR — Unified Suspicious Activity Report(s) 42 AssErs 42 Financial Account(s) 42 TARGET 10 — 43 BIOGRAPHICAL/IDENTIFYING DATA 43 ADDRESSES 43 BORDER CROSSINGS 43 Border Crossings - Air 43 LINKED INVESTIGATIONS 44 CRIMINAL HISTORY/NCIC 44 Offline NCIC 44 FINANCIAL INFORMATION 45 USAR — Unified Suspicious Activity Report(s) 45 CTR - Currency Transaction Report(s) 45 TARGET 11 - 47 BIOGRAPHICAL/IDENTIFYING DATA 47 ADDRESSES 47 COMMUNICATIONS 47 Telephone Numbers 47 LINKED INVESTIGATIONS 47 CRIMINAL HISTORY/NCIC 48 Offline NCIC 48 FINANCIAL INFORMATION 49 USAR — Unified Suspicious Activity Report(s) 49 AssErs 49 Financial Account(s) 49 TARGET 12 — 50 BIOGRAPHICAL/IDENTIFYING DATA 50 ADDRESSES 50 COMMUNICATIONS 50 Telephone Numbers 50 LINKED INVESTIGATIONS 51 CRIMINAL HISTORY/NCiC 51 Offline NCIC 51 FINANCIAL INFORMATION 52 USAR — Unified Suspicious Activity Report(s) 52 AssErs 53 Financial Account(s) 53 SENSITIVE BUT UNCLASSIFIED iv EFTA00173957  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 TARGET 13 - 54 BIOGRAPHICAL/IDENTIFYING DATA 54 ADDRESSES 54 COMMUNICATIONS 55 Telephone Numbers 55 BORDER CROSSINGS 55 Border Crossings - Air 55 LINKED INVESTIGATIONS 55 CRIMINAL HIsToRWNCIC 56 Offline NCIC 56 FINANCIAL INFORMATION 57 TARGET 14 - 58 BUSINESS IDENTIFYING DATA 58 ADDRESSES 58 COMMUNICATIONS 59 Telephone Numbers 59 LINKED INVESTIGATIONS 59 FINANCIAL INFORMATION 59 ASSOCIATE IDENTIFYING INFORMATION 60 Associates 60 TARGET 15 - 61 BUSINESS IDENTIFYING DATA 61 ADDRESSES 61 COMMUNICATIONS 62 Telephone Numbers 62 LINKED INVESTIGATIONS 62 FINANCIAL INFORMATION 62 ASSOCIATE IDENTIFYING INFORMATION 63 Associates 63 SENSITIVE BUT UNCLASSIFIED EFTA00173958  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 **CAUTION** This product may contain active hyperlinks to internet websites and email addresses. Please use caution when navigating the contents of this publication. Hvperlinks will be identified in red. Analytical Findings Background: A request was submitted by the Drug Enforcement Administration (DEA) New York NY for all re ' .rtin available to the OCDETF Fusion Center OFC for • Jeffre EPSTEIN. ; and . DEA reporting indicates the above individuals are involved in illegitimate wire transfers which are tied to illicit drug and/or prostitution activities occurring in the U.S. Virgin Islands and New York City. • Analytical Findings: This Target Profile product was prepared from a series of queries against the available OFC databases. Reporting relative to the subjects was found in Customs and Border Protection (CBP); DEA; DOS Non-immigrant Visas (DOS NIV); Diplomatic Security Service (DSS); Federal Bureau of Investigation (FBI); Financial Crimes Enforcement Network (FinCEN) Gateway; and Immigration and Customs Enforcement (ICE) databases as well as the commercial database Accurint. Through a phone conversation, the requestor indicated recent financial information on the targets would be beneficial to the investigation. o Financial Information (Bank Secrecy Act Warnings Apply): Analyst's Note 1: Many of their financial reports listed below include many/all of the targets as multiple subjects. Analyst's Note 2: Only financial reporting from 2010 through 2015 is included in this report. Older financial information on the targets is available. • is a subject of three 2015 USARs totaling $4,193,637. See attachment I for more information. • is a subject of three 2015 USARs totaling $4,193,637. See attachment 1 for more information. • is a subject of three 2015 USARs totaling $2,754,983. See attachment 1 for more information. • Jeffrey EPSTEIN is a subject of seven USARs (4 in 2015, 2 in 2014, and 1 in 2013) totaling $5,672, 21. See attachment 1 for more information. • Jeffrey EPSTEIN and are subjects together in three Unified Curren Transaction Reports (UCTR) (1 in 2014 and 2 in 2013) totaling $102, 648. reportedly conducted transactions on Jeffrey EPSTEIN's behalf. See Jeffrey EPSTEIN's financial information section for more information. SENSITIVE BUT UNCLASSIFIED Page 1 of 63 EFTA00173959  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 • Jeffrey E EIN is a subject of eight CTRs (2 in 2011 and 6 in 2010) totaling $233,397. is an additional subject of one of these CTRs. See attachment 2 for more information. • is a subject of a 2015 USAR for $157,898. See attachment I for more information. • is a subject of a 2014 UCTR for 0 000 in which he conducted a withdrawal(s) on behalf of See financial information section for more information. • is a subject of three USARs (2 in 2015 and 1 in 2014) totalin 4 236 995. See attachment 1 for more information. • and are subjects of a 2011 CTR in which conducted USD and Euro transactions on behalf of financial information section for more information. is a subject of two USARs (1 in 2015 and 1 in 2013) totaling 898. See attachment I for more information. • and are the subjects of three 2013 UCTRs totaling $157,152. FinCEN indicates cashed negotiable instruments the businesses' behalf. See financial information and corporate/business affiliations sections for more information regarding the UCTRs and res ctively. • and are the subjects of 22 CTRs (1 in 2013, 9 in 2012, 7 in 2011, and 5 in 2010) totaling $730,000. See attachment 3 for more information. • is a subject of three 2015 USARs totaling $2,754,983. See attachment 1 for more information. • is a subject of two 2015 USARs totaling $4,079,102. See attachment I for more information. • is a subject of three 2015 USARs, totaling $4,193,637. See attachment 1 for more information. • and are subjects together in two CTRs (2011 and 2010) in which conducted deposits on the company's behalf. See financial information section for more information. • is a subject of two 2015 USARs totaling $4,079,102. See financial information section for more information is the subject of a 2012 USAR for $45,107. See financial information section for more information. • is a subject of two 2015 USARs totaling $4,079,102. See IDZK W KA' financial inf rmatiration for more information. • Is a subject of two 2015 USARs totaling $4,079,101. See attachment 1 for more information • is a subject of three 2015 USARs totaling $4,193,637. See attachment 1 for more information. SENSITIVE BUT UNCLASSIFIED Page 2 of 63 EFTA00173960  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 o Cases and Contacts: The targets are subjects in the following case: ase File Title/ Case Agency/Location Case Number Date Opened Operation Agent(s)/ Status/Date C Name Phone No. DEA/ Pending C1-11-0049 12/17/2010 New York, NY Judicial SENSITIVE BUT UNCLASSIFIED Page 3 of 63 EFTA00173961 SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 SENSITIVE BUT UNCLASSIFIED Page 4 of 63 EFTA00173962 SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 SENSITIVE BUT UNCLASSIFIED Page 5 of 63 EFTA00173963  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 Criminal History/NCIC Offline NCIC GUIDANCE NOTE An Offline NCIC repon lists other law enforcement agencies that have previously queried the same individual. This repon does not necessarily mean the agencies listed on the offline NCIC report have additional documents on that individual. By default. Olt requests will query NCIC for the last 2 years of data unless otherwise requested by the rcquestor. The table below is a summary by Agency. The detailed information is contained in the corresponding attached Offline NCIC file, i.c. - Offline NCIC Results for Target I IMMIDD(fYYY HH:NIM:SS).xls", which provides the dateline and Agency ORI terminal the target was queried. When contacting the appropriate LE agency. the LE agency will need the specific information outlined in the attachment to provide further details regarding their initial query. Offline NCIC inquiries are records where individuals were queried by local, state or federal law enforcement (LE) agencies at a particular point in time. Offline NCIC checks identify the law enforcement agencies that have previously queried a target. For example, using Offline NCIC checks can provide the following insight: • Knowing what other agencies are inquiring about your target can be a primary de-confliction tool in bringing various agencies together. • Pinpointing geographical locations where target previously traveled. • Discoverine tareet associations based on vehicle stops. SENSITIVE BUT UNCLASSIFIED Page 6 of 63 EFTA00173964  SENSITIVE BUT UNCLASSIFIED OFC-TP-15.12392 SODOFC-15.12392 Date of Report: May 18, 2015 Financial Information WARNING The enclosed information 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 Chapter X. The information is sensitive in nature and is to be treated accordingly. The information may be used only for a purpose consistent with a criminal. tax. or regulatory investigation or proceeding, or in the conduct of intelligence or counterintelligence activities, including analysis. to protect against international 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 BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity. akin to confidential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. WARNING Note - SAR fling- This report contains a Suspicious Activity Report (SAR) of suspected criminal activity. filed by a U.S. financial institution. SARs arc utli evidence. but contain information that, when further investigated. may produce evidence of criminal activity. Law enforcement personnel that use SAR information as part of investigative efforts may nol: 1) Confront a customer of a financial institution with a SAR. or 2) Include a SAR as an attachment to an affidavit or other legal document. If it is anticipated that there may be a need to disclose the actual SAR filing as pert or a judicial proceeding. law enforcement personnel must coordinate that potential disclosureixith_FinCENs Office of Chief Counsel. The prohibition regarding SAR disclosure does not preclude law enforcement personnel from discussing a SAR filed by a bank. or the contents of such SAR. with Federal bank supervisory personnel. Federal bank supervisory agencies, along with FinCEN. promulgated the regulations requiring banks to report suspicious activity by filing SARs. Accordingly. these agencies have access to SARs and have the authority to provide direction with regard to the handling and disclosure of SARs. Notwithstanding the general prohibition on the re-dissemination of a SAR without the prior approval of FinCEN. law enforcement personnel may. without prior authorization, disclose a SAR to appropriate domestic law enforcement personnel and prosecutors working on the same or a related investigation. or to such domestic law enforcement personnel that are part of the same joint task force, provided the disclosing agency satisfies the conditions set forth in the Re-dissemination Guidelines Jar Bank Secrecy Act Information (November 28. 2007). SENSITIVE BUT UNCLASSIFIED Page 7 of 63 EFTA00173965 SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May IS, 2015 SENSITIVE BUT UNCLASSIFIED Page 8 of 63 EFTA00173966  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May IS, 2015 Criminal History/NCIC Offline NCIC GUIDANCE NOTE An GI 'line NCIC report lists other law enforcement agencies that have previously queried the same individual. This report does not necessarily mean the agencies listed on the offline NCIC report have additional documents on that individual. By default. OFC requests will query• NCIC for the last 2 years of data unless otherwise requested by the requestor. The table below is a summary by Agency. The detailed information is contained in the corresponding attached Offline NCIC file, i.e. - Offline NCIC Results for Target I INIM/DDfYYYY HH:fsINI:SS).xls", which provides the datetime and Agency ORI terminal the target was queried. When contacting the appropriate LE agency. the LE agency will need the specific infommtion outlined in the attachment to provide further details regarding their initial query. Offline NCIC inquiries are records where individuals were queried by local, state or federal law enforcement (LE) agencies at a particular point in time. Offline NCIC checks identify the law enforcement agencies that have previously queried a target. For example, using Offline NCIC checks can provide the following insight: • Knowing what other agencies are inquiring about your target can be a primary de-confliction tool in bringing various agencies together. • Pinpointing geographical locations where target previously traveled. • Discovering target associations based on vehicle stops. SENSITIVE BUT UNCLASSIFIED Page 9 of 63 EFTA00173967  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 Financial Information WARNING The enclosed information 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 Chapter X. The information is sensitive in nature and is to be treated accordingly. The information may be used only for a purpose consistent with a criminal, tax. or regulatory• investigation or proceeding. or in the conduct of intelligence or counterintelligence activities. including analysis. to protect against international terrorism. See 31 U.S.C. 53 II. 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 BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity. akin to confidential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. WARNING Note - SAR (Isaac_ This report contains a Suspicious Activity Report (SAR) of suspected criminal activity. filed by a U.S. financial institution. SARs arc not evidence, but contain information that. when further investigated. may produce evidence of criminal activity. Law enforcement personnel that use SAR information as part of investigative efforts may not: I ) Confront a customer of a financial institution with a SAR. or 2) Include a SAR as an attachment to an affidavit or other legal document. If it is anticipated that there may be a need to disclose the actual SAR filing as part or a judicial proceeding. law enforcement personnel must coordinate that potential disclosure with FinCEN's Office of Chief Counsel. The prohibition regarding SAR disclosure does not preclude law enforcement personnel from discussing a SAR filed by a bank. or the contents of such SAR. with Federal bank supervisory personnel. Federal bank supervisory agencies, along with FinCEN. promulgated the regulations requiring banks to report suspicious activity by filing SARs. Accordingly. these agencies have access to SARs and have the authority to provide direction with regard to the handling and disclosure of SARs. Notwithstanding the general prohibition on the re-dissemination of a SAR without the prior approval of FinCEN. law enforcement personnel may. without prior authorization, disclose a SAR to appropriate domestic law enforcement personnel and prosecutors working on the same or a related investigation. or to such domestic law enforcement personnel that are part of the same joint task force. provided the disclosing agency satisfies the conditions set forth in the Re-dissemination Guidelines fin. Bank Secrecy Act Information (November 28. 2007). SENSITIVE BUT UNCLASSIFIED Page 10 of 63 EFTA00173968 SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 SENSITIVE BUT UNCLASSIFIED Page 11 of 63 EFTA00173969  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 Offline NCIC GUIDANCE NOTE An Offline NCIC rcpon lists other law enforcement agencies that have previously queried the same individual. This report does not necessarily moan the agencies listed on the offline NCIC report have additional documents on that individual. By default. OIC requests will query NCIC for the last 2 years of data unless otherwise requested by the rcquestor. The table below is a summary by Agency. The detailed information is contained in the corresponding attached Offline NCIC file. i.c. "Offline NCIC Results for Target I antalirtYYY HH:MNI:SS).xls", which provides the datetimc and Agency ORI terminal the target was queried. When contacting the appropriate LE agency. the LE agency will need the specific information outlined in the attachment to provide further details regarding their initial query. Offline NCIC inquiries are records where individuals were queried by local, state or federal law enforcement (LE) agencies at a particular point in time. Offline NCIC checks identify the law enforcement agencies that have previously queried a target. For example, using Offline NCIC checks can provide the following insight: • Knowing what other agencies are inquiring about your target can be a primary de-confliction tool in bringing various agencies together. • Pinpointing geographical locations where target previously traveled. SENSITIVE BUT UNCLASSIFIED Page 12 of 63 EFTA00173970  SENSITIVE BUT UNCLASSIFIED OFC-TP-15-12392 SODOFC-15.12392 Date of Report: May 18, 2015 Financial Information WARNING The enclosed information 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 Chapter X. The information is sensitive in nature and is to be treated accordingly. The information maybe used only for a purpose consistent with a criminal. tax. or regulatory• investigation or proceeding. or in the conduct of intelligence or counterintelligence activities. including analysis. to protect against international 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 BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity. akin to confidential infommnt tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. WARNING Note - SAR Usage: This report contains a Suspicious Activity Report (SAR) of suspected criminal activity. filed by a U.S. financial institution. SARs are not evidence. but contain information that, when further investigated. may produce evidence of criminal activity. Law enforcement personnel that use SAR information as pan of investigative efforts may not: I ) Confront a customer of a financial institution with a SAR. or 2) Include a SAR as an attachment to an affidavit or other legal document. If it is anticipated that there may be a need to disclose the actual SAR filing as part of a judicial proceeding. law enforcement personnel must coordinate that potential disclosure with FinCEN's Office of Chief Counsel. The prohibition regarding SAR disclosure does not preclude law enforcement personnel from discussing a SAR filed by a bank. or the contents of such SAR. with Federal bank supervisory personnel. Federal bank supervisory agencies. along with FinCEN. promulgated the regulations requiring banks to report suspicious activity by filing SARs. Accordingly. these agencies have access to SARs and have the authority to provide direction with regard to the handling and disclosure of SARs. Notwithstanding the general prohibition on the re-dissemination of a SAR without the prior approval of FinCEN. law enforcement pers