EFTA02808240
Court Records
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EFTA02808240, U.S. Department of Justice, Epstein Files release (Court Records). Primary source: https://www.justice.gov/epstein/files/Court%20Records/Government%20of%20the%20United%20States%20Virgin%20Islands%20v.%20JPMorgan%20Chase%20Bank%2C%20N.A.%2C%20No.%20122-cv-10904%20%28S.D.N.Y.%202022%29/EFTA02808240.pdf. Retrieved via Epstein Files Transparency Act Resources, https://tommycarstensen.com/epstein/data/documents/court/02808/EFTA02808240.html.
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Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 1 of 19 UNITED STATES VIRGIN ISLANDS ECONOMIC DEVELOPMENT COMMISSION INDUSTRIAL PARK DEVELOPMENT CORPORATION Taveactit4 Dftegus April 17, 2008 Cecile DeJongh Manager Financial Trust Company, Inc. 6100 Red Hook Quarter B-3 St. a VI 00802 Dear Mrs. DeJongh: A -compliance review has been completed on Financial Trust Company, Inc. Enclosed for your review and commentary is a copy of the compliance report which covers the period of April 1, 1999 to December 31, 2006. Please respond to this compliance report within ten (10) working days from receipt of this letter. If you have any questions concerning this matter, do not hesitate to contact me at 774-8104, Ext. 236. Sincerely, Dire or of Com ance Cc: E. Clouden, Chief Executive Officer a, Jr., Assistant Chief Executive Officer Francois Dominique, Director Application & Intake Sandra Bess, Compliance Officer A Division OF THE ECONOMIC DEVELOPMENT AUTHORITY P.O. Box 305038 • ST. U.S. VERGER ISLANDS 00803 • (340) 774-8104 • Fax (340) 774-8106 9116 1O74csTREET • ST. OIX, .S. Vatcw ISLANDS 00840 • (340) 773-6499 • Fax (340) 773-7701 TOLL FREE 1-877.432-8784 • www usviedaorg CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022897 EFTA02808240 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 2 of 19 UNITED STATES VIRGIN ISLANDS audeavut Dream. COMPLIANCE REPORT Financial Trust Company, Inc. As of December 31, 2006 SUMMARY HIGHLIGHT: o Financial Trust Company, Inc. has enjoyed seven (7) years of tax benefits. o Financial Trust Company, Inc. met and exceeded the capital investment of US $300,000. o Capital Expenditures from 1999 to 2006 were $570,067 of which 96% ($546,447) was procured locally. o Goods and Services from 1999 to 2006 were $4,252,064 of which 77% was procured locally. o Financial Trust Company, Inc. met its employment requirement of 11 full- time employees. o Financial Trust Company, Inc. met its residency requirement. o Financial Trust Company, Inc. met the 20% management, technical and supervisory requirement o Financial Trust Company, Inc. met the requirements of Special Conditions #1, #2, #3 and #5. o Financial Trust Company, Inc. did not specifically meet the requirements of Special Condition #4. o Financial Trust Company, Inc. complied with the requirements of the procurement process. o Financial Trust Company, Inc. met the reporting requirements. CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022898 EFTA02808241 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 3 of 19 UNITED STATES VIRGIN ISLANDS i tif f Tociateut Vite-a4st Title 29, Chapter 12 VIC, Section 715(a) states in part "upon proper application or reapplication, public hearing and in compliance with all other relevant provisions of this chapter pertaining to the grant of initial benefits, as determined and required by the Commission, any recipient of industrial development benefits (sic), may be granted an extension, modification, or renewal of benefits..." HISTORY: Financial Trust Company, Inc. was granted tax exemption benefits to conduct the business of financial and economic consulting, money management, investment advisory and fiduciary services for its clients. Such clients will include individuals, trusts, foundations and business entities. Benefits were granted for a period of ten (10) years commencing and terminating as follows: Commencement Termination Income Taxes Gross Receipt Taxes Excise Taxes (Raw Materials) Excise Taxes (Equip., Mach.) Dividend Withholdings Interest Withholdings Real Property Tax April 1, 1999 April 1, 1999 January 1, 2000 January 1, 2000 April 1, 1999 April 1, 1999 January 1, 2000 March 31, 2009 March 31, 2009 December 31, 2009 December 31, 2009 March 31, 2009 March 31, 2009 December 31, 2009 On November 6, 1998, the corporation filed Articles of Incorporation with the Office of the Lieutenant Governor. A Certificate of Incorporation, authorizing them to conduct business in the Virgin Islands was issued on November 30, 1998. Upon completing an application to the Economic Development Commission (EDC) on February 22, 1999, the Beneficiary tax benefits were approved by the Governor of the Virgin Islands on November 26, 1999. The certificate of benefits was executed by the Chairman of the EDC Board of Commissioners on March 21, 2000. Financial Trust Company, Inc. has enjoyed seven (7) years of benefits. Financial Trust Company, Inc. is solely owned by Mr. Jeffrey Epstein. Page 2 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022899 EFTA02808242 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 4 of 19 UNITED STATES VIRGIN ISLANDS ?gat 1 A %waters Leash INVESTMENT: Commencing no later than one (1) year from April 1, 1999, the Beneficiary shall be required to invest no less than U.S. $300,000 excluding inventory, in accordance with the EDC Rules and Regulations. FINDINGS: As of December 31, 1999, Financial Trust Company, Inc. met the investment requirement of $300,000. During the period covered by this report the Beneficiary made additional investments totaling $270,067. Financial Trust Company, Inc. invested a total of $570,067 as of December 31, 2006. CAPITAL EXPENDITURE: YEAR Eligible VI Supplier VI Supplier Non-VI Supplier Total 1999 - 326,228 - 326.226 2000 150,539 23,030 14,220 187,789 2001 - 1,599 880 2,479 2002 572 21,860 505 22,937 2003 - 12,906 - 12,906 2004 - - 6,215 8,215 2005 - 1,781 744 2,525 2006 1,399 6,535 1,056 8,990 Grand Total 152,510 393,937 23,820 _ 570,067 FINDINGS: From 1999 to 2006 a total of $570,067 was procured in capital expenditures. Of the expenditures categorized; 69% ($393,937) were purchases from Virgin Islands Suppliers, 27% ($152,510) were procured from Eligible Virgin Islands Suppliers for Leasehold Improvements and Office Equipment and the remaining 4% ($23,620) from Non-Virgin Islands' suppliers for Office Equipment and Furniture and Fixtures. Page 3 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022900 EFTA02808243 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 5 of 19 4 UNITED STATES VIRGIN 'SUMS napit y, 4, i 11V ; as ekveditsa tram. CAPITAL EXPENDITURES 1999 - 2006 4% GOODS AND SERVICES: 27% O Eligible Vi Supplier NM Supplier o Non-VI Supplier YEAR Eligible VI Supplier VI Supplier Non-VI Supplier Total 1999 - 30,338 3,615 33,953 2000 281,142 154,391 52,735 488,268 2001 47,558 170,589 109,194 327,441 2002 47,635 453,622 238,419 739,676 2003 44,621 415,191 299,441 759,253 2004 78,551 445,240 166,883 690,654 2005 36,443 435,554 59590 531,587 2006 45,799 596,029 39,404 681,232 Grand Total 581,749 2,700,954 989,381 4,252,064 FINDINGS: The total expended for goods and services from 1999 through 2006 was $4,252,064. Purchases from Virgin Islands suppliers totaled $2,700,954 (64%); $969,361 (23%) was spent with Non-Virgin Islands' suppliers; and the remaining $581,749 (14%) was procured from Eligible suppliers. Page 4 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022901 EFTA02808244 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 6 of 19 ° UNITED STATES VIRGIN ISLANDS Iseoattact preetat GOODS & SERVICES 1999 - 2005 O Eligible VI 1 2640 5% Supplier ■ VI Supplie 59% O Non-VI Supplier LOCAL PROCUREMENT: In accordance with Division 10 of the Economic Development Commission Rules and Regulations, the beneficiary must comply with procurement procedures (Section 708-701 to 708-718). FINDINGS: From 1999-2006, the beneficiary's total expenditures were $4,822,131. 64% ($3,094,891) of the purchases were made from Virgin Island Suppliers of which the majority was spent on leasehold improvements, legal/accounting, and charitable contributions. 21% ($992,981) were made from Non-Virgin Islands Suppliers and the remaining 15% ($734,259) was purchased from Eligible Virgin Islands Suppliers. The non local expenditures totaling $992,981 comprised mainly of equipment, furniture/fixtures, MI market services and legal/accounting. A total of $767,057 was procured for legal/accounting and market services which are exempt procurement in accordance with Section 708-704 (e) of the EDC Rules and Regulation; $162,900 included purchases of insurance, travel, dues and subscriptions, supplies and repairs and maintenance. The Beneficiary indicated that these were aggregate purchases from 2000 to 2006 which included computer supplies and CCH Tax guides. The remaining capital expenditure were non-local Page 5 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022902 EFTA02808245 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 7 of 19 UNITED STATES VIRGIN ISLANDS Investstet Dream purchases for office equipment and furniture and fixture totaling $22,564. Several purchases were exempt in accordance with the EDC Rules and Regulations (promulgated 1981), section 708-704 (b) and Section 708-705 (a). In January 2000, after approval of benefits and prior to receipt of certificate, the Beneficiary purchased furniture totaling $3,372 from Crate and Barrel, a non- Virgin Islands supplier and in March 2000 a specialized computer in the amount of $4,947 was purchased from Micro Computer. In accordance with the EDC Rules and Regulations Section 708-707 (Rules promulgated 1981), the Beneficiary was required to provide proof that solicited quotes were on a competitive basis. The Beneficiary stated that these items were specific brands not available in the Virgin Islands. Total Procurement 1999 - 2005 100% 80% GO% 40% cat) Ea) 22,584 387,402 Page 6 .4 Goods & Svcs 929,957 2,104,925 535,950 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022903 EFTA02808246 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 8 of 19 • UNITED STATES VIRGIN ISLANDS Toutedatt nes* EMPLOYMENT: The Beneficiary shall employ no later than one year from September 7, 1999 no less than eleven (11) persons on a full-time basis who are residents of the Virgin Islands as defined in Title 29, V.I. Code Section 703(e). Also, in accordance with Section 710(a) Title 29, Chapter 12, VIC (Amended 1992), after the third year of operation, a beneficiary shall be required to have at least 20% of its management, supervisory, and/or technical positions filled by residents of the United States Virgin Islands unless granted a waiver by the Commission. §708-605 Full-Time Employment For the purposes of this division, "full-time" employees or employment shall mean employment, on a permanent and continuous basis, for thirty-two hours or more per week. FINDINGS: YEAR TOTAL AVERAGE FULL TIME AVERAGE V.L RES. AVERAGE % VI Re. AVERAGE MGMT. 20% V.L MGMT 1999 1 1 0 0% 1/1 0% 2000 10 10 10 100% 6/6 100% 2001 II 11 11 100% 6/6 100% 2002 II II 11 100% 6/6 100% 2003 III II 11 100% 6/6 100% 2004 12 11 12 100% 7/7 100% 2005 II II 11 100% 7/7 100% 2006 _ 11 11 11 100% 6/6 1000,. From September 6, 2000 to December 31, 2006 the average full-time employment ranged from ten (10) to twelve (12) employees. The Beneficiary met the requirement of eleven (11) full-time employees, and also met the 80% residency requirement and the 20% management requirement for the period covered in this report. Page 7 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022904 EFTA02808247 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 9 of 19 UNITED STATES VIRGIN ISLANDS Tieveara neast In the second quarter of 2004, Tequasi Hendricks a senior at the Eudora Kean High School was hired as a part-time clerical employee. The Beneficiary stated Ms. Hendricks walked into the office off the street, inquired about a job, filled an application and was hired. They stated that Ms. Hendricks exhibited exceptional work habits and was therefore hired as a fill) time Researcher/Bookkeeper after graduating from high school in 2005. SPECIAL CONDITIONS: The following conditions shall apply: 1. The Beneficiary shall provide all employees with health care insurance, funded by the Beneficiary • From 2000 to 2001, the Beneficiary provided Health, Vision, Life and Dental insurance to all full-time employees. Health and dental coverage was also provided to employees' eligible dependents through Canada Life Assurance. ■ From 2002 to 2006, the Beneficiary provided Health, Dental and Life Insurance through United HealthCare Insurance Company. The Beneficiary paid 100% of the insurance premium for each eligible employee except Tequasi Hendricks whom the Beneficiary stated preferred to be covered by her mother's insurance. The Beneficiary also paid 100% dental and health insurance coverage for the eligible dependents of its employees. • Canada Life Assurance and United HealthCare Insurance Company are both registered with the Lieutenant Governor's Office of Banking and Insurance. Page 8 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022905 EFTA02808248 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 10 of 19 UNITED STATES VIRGIN ISLANDS 414:a T.wedeats (teas 2. The applicant shall provide all employees a qualified retirement plan funded by the Beneficiary. • In 2001, the Beneficiary provided all full-time employees a SEP/SRA Plan with Merrill as Custodian. From 2002 to 2006 the Beneficiary establitg l an American Funds Savings Incentive Match Plan for Employees ("SIMPLE") incorporated with an Individual Retirement Agreement (IRA). The Simple IRA is offered to all employees receiving at least $5,000 in compensation. The Beneficiary makes a matching contribution equal to 100% of elective deferrals up to a limit of 3% per calendar year. It is noted that from 2000 to 2005 eight employees, and in 2006 nine employees, participated in the Simple IRA Plan facilitated by the Beneficiary. 3. The applicant shall provide employee training and tuition reimbursement program for eligible employees. The Beneficiary provided documentation to show the training provided to employees. • In 2000 the Beneficiary provided in-house training on Power-point to all staff and specialized training in Communication, Typing, CPA Review and Finance to the accounting employees. • Training in Conversation Power Video was provided in 2001 to all staff. Computer classes were provided to the messenger/custodian, Front Desk Seminar to the receptionist and CPA reviews and books purchased for the accounting and research staff. • The entire staff was provided Quick-books training in 2002 and the accounting staff with CPE and CPA courses. • In 2003 the entire staff attended three (3) different Skill-path Seminars and one (1) course in CPE continuing education. • In 2004, the Skill-path Seminars were provided to the receptionist, accounting and research staff. Tax Seminars and CPA review courses were provided. Page 9 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022906 EFTA02808249 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 11 of 19 • UNITED STATES VIRGIN ISLANDS Tiagedtattia neat- • CPE Tax Seminars and classes with UVI Cell were offered in 2005 to the accounting staff. • In 2006, the Network Administrator was provided training with Skill-path. The Controller attended two (2) courses in CPA continuing education. The Bookkeeper registered for a one-day course at the University of the Virgin Islands - Intro to Insurance and Captive Management. And the Receptionist and Custodian / Messenger attended a Conference on the Status of Women. Additionally, the Beneficiary provided tuition reimbursement to II in 2002, Tequasi Hendricks in 2003 and Jermaine Ruan in for classes taken at UVI. 4. The applicant shall make annual contributions of $50,000 or one percent (1%) of gross receipts tax exemption value, whichever is greater, to be distributed annually as follows: (a) 50% to educational scholarships (b) 25% for charity (c) 25% for co-op marketing with EDC However, after issuance of its certificate, applicant shall prepay the first five (5) years of contribution fixed at $50,000, or the sum of $250,000, to be distributed as follows: (a) $187,500 to a tax-exempt entity from which annual distributions of not less than $25,000 to educational scholarship and $12,500 to charity shall be made, and (b) $62,500 for co-op marketing with IDC Page 10 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022907 EFTA02808250 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 12 of 19 , UNITED STATES VIRGIN ISLANDS Toweled/a nreast CERTIFICATE REQUIREMENT: Year Gross Receipt Gross Receipt Exemption 1% Gross Contribution Receipt per EDC ErnValue"P ticm Certificate Alter Certificate issued - five (5) years prepayment 250,000 2000 2001 2002 2003 2004 2005 2008 ■ Total Contribution per EDC Certificate 50,000 50,000 350,000 Tax Exempt Entity 50% to Educational Scholarships 25% Charity 25% Co-op Marketing with EDC 125,000 62,500 82,500 - - - - - - - - - - - - - - - 25,000 12,500 12,500 25,000 12,500 12,500 175,000 87,600 87,500 The Beneficiary provided documentation for the period January 2000 to December 2006 showing total contributions of $1,762,465; $313,875 from Financial Trust Co., Inc. and $1,448,590 from the J. Epstein Foundation; made to charities, educational scholarships, educational symposiums (other) and Co-op Marketing to the EDC. Total Contributions J. Epstein Foundation Educational Scholarships ChaCharitymarketinn ' Co-op with ErC Z Other at Educational bielIgibIe Symposiums Contributions Financial Trust Co., Inc. 313,875 187,500 21,625 11,053 75,000 4,397 14,300 Certificate Requirement 350,000 187,500 50,000 25,000 87,000 - - Variance (36,125) - (28,375) (13,947) (12,500) 4,397 14,300 J. Epstein Foundation 1,448,590 - 649,431 434,497 - 357,662 7,000 Over/Short Contributions 1,412,465 - 621,056 420,550 (12,500) 362,059 21,300 Page 11 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022908 EFTA02808251 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 13 of 19 UNITED STATES VIRGIN ISLANDS UNI TED P Sweattu neat In 2005 and 2006, Financial Trust Co. Inc. did not directly contribute total requirement in charitable contributions in the area of educational scholarship and charity. However, it is noted that additional contributions were made from the J. Epstein Foundation. A total of $1,448,590 was reported, of which $1,261,000 was over the requirement of $187,500 prepaid by Financial Trust Co., Inc. Mr. J. Epstein, sole owner of Financial Trust Company Inc. personally funds the J. Epstein Foundation. In addition, the Beneficiary was initially notified that a contribution of $12,500 was not due for the 2006 Co-op Marketing with EDC However during this audit, reconciliation of the Beneficiary's contribution account identified an error in recording a duplicate payment. Adjustments were made and the Beneficiary was notified of payment due and restitution to be made accordingly. Following are actual contributions made by Financial Trust Co., Inc and the J. Epstein Foundation: ACTUAL CONTRIBUTIONS: FINANCIAL TRUST CO , INC. Year Total Contributions J. Epstein Foundation Educational Scholarships J Charity O Ethpaerte; / Co-op marketing with EDC ineligible 2000 189,401 187,500' - 1,150 551 - 200 2001 80,920 - 17,620 600 50 62,500 150 2002 600 - 600 - - - 600 2003 1,313 - - 808 5 - 500 2004 13,528 - - 7,000 3,578 - 2,950 2005 18,081 - 1,110 625 48 12,500 3,800 2006 10,032 - 2,295 870 167 - 8,700 Totals 313, 875 187,500 21,625 11,053 4,397 75,000 14,300 $187,500 prepaid to the J. Epstein Foundation for 5 years (2000 — 2005) Page 12 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022909 EFTA02808252 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 14 of 19 • UNITED STATES VIRGIN ISLANDS litev. a.ant ^ti %oats neat o In 2000, the Beneficiary set up and made an initial payment of $187,500 to a tax exempt entity; the J. Epstein Virgin Islands Foundation, Inc. as requested in the EDC benefits certificate. The Beneficiary also made an additional charitable contribution of $1,901. o In 2001, the Beneficiary made a total contribution of $80,920. Educational Scholarship totaling $17,620 to the Ruby Rutnik Scholarship Fund and Antilles School Inc. Contributions in the amount of $600 was made to several charities and a contribution of $50 was reported as other for personal contributions by Mr. J. Epstein. And a payment of $62,500 was made to the EDC for Co-op marketing. o In 2002, a total of $600 was contributed by the Beneficiary toward educational scholarships. o In 2003, the Beneficiary contributed $808 primarily to educational scholarships. o In 2004, the Beneficiary contributed a total of $13,528; $7,000 was given to charities and $3,578 reported as other for personal contributions made by J. Epstein. o In 2005, the Beneficiary contributed a total of $18,081; $1,110 made to educational scholarships, a shortage of $23,890, $625 to charities, a shortage of $11,875, and a payment of $12,500 to the EDC for Co-op marketing. o In 2006, the Beneficiary contributed a total of $10,032; $2,295 given for educational scholarships, a shortage of $22,705, $870 to charities, a shortage of $24,130 and $167 reported as other for personal contributions by J. Epstein. Page 13 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022910 EFTA02808253 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 15 of 19 UNITED STATES VIRGIN ISLANDS irget tO*t Tneseaters nesse- ACTUAL Contsurrons: J. EPSTEIN FOUNDATION Year Total Contribution Educational Schointrips CM.II, Educational Symposium Ineligible Contribution 2000 38,000 25,000 13,000 - - 2001 11,1002 500 10,600 - - 2002 281,477 120,281 90,100 71,096 - 2003 179,888 135,250 43,136 - 1,500 2004 263,976 162,610 95,866 5,000 500 2005 250,314 90,200 138,019 20,595 1,500 2006 423,837 115,590 43,776 260,971 3,500 Totals 1,448,590 649,431 434,497 357,662 7,000 The J. Epstein Foundation is a tax exempt entity established by Financial Trust, Company Inc., the Beneficiary, primarily for making charitable contributions to the Virgin Islands community. o In 2000, the J. Epstein Foundation received $187,500 from Financial Trust Company, Inc. as required by the Beneficiary's certificate. The J. Epstein Foundation made a contribution of $38,000; $25,000 to the Community Foundation of the VI for educational scholarships and $13,000 to charities such as the American Cancer Society, the St. Croix Shriner's Club, Caribbean Light Lode Scholarship Fund, Beacon Schools and the United Way of St. St. John and St. Croix. The charitable contribution was $500 over the certificate's commitment. o In 2001, the J. Epstein Foundation contributed $500 to educational scholarships and $10,600 to charities. These charities included: Antilles School, Inc., Charlotte Amalie High School PED, Women's Business Center, the St. Baseball Explorers and the St. Youth Soccer Association. These contributions were $26,400 2 Per benefits certificate: commitment was not made. Page 14 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022911 EFTA02808254 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 16 of 19 UNITED STATES VIRGIN ISLANDS a./ Tmceae'rs neat short of the certificate's commitment: $24,500 — educational scholarships and $1,900 - charities. o In 2002, All Saints School, UVI/Tom Joyner Foundation, Inc. and Antillies School received $I20,281 toward educational scholarships. A total of $90,100 was given as charitable contributions to: Antilles School, Arts Alive, Beacon School, the Safety Zone, Elrod Hendricks Little League West and Zero Tolerance Inter-Neighborhood Basketball. Additionally, a total of $71,096 was contributed to an Educational Symposium on Artificial Intelligence. A member of the Beneficiary's management staff stated that Mr. Epstein likes to enable students of a conununity to become accessible to the world of science and other topics. He therefore invited some famous scientists to the Virgin Islands for a symposium. The symposium was advertised via all the Virgin Islands newspapers and radio airwaves. An invitation was also extended to public and private school students. These contributions were $243,977 over the certificate's commitment. o In 2003, a total of $135,250 was made for educational scholarships to All Saints Cathedral School, Antillies School, Ruby Rutnik Scholarship Fund, Inc., Senator Carlton Dowe Summer Enrichment Program and St. Mary's School. The Boys and Girls Club, Cheetahs Track Club, Kidscope, Inc., St. / St. John Sickle Cell Disease Association, We From Upstreet Inc., V.I. Montessori School and the RLS Hospital Cancer Fund are some organizations which received charitable contributions totaling $43,136. A contribution was also made to the Auburn University for the Ed M, Jr. Symposium. Mr. is a Virgin Islands resident who has excelled in academia. These contributions were $142,386 over the certificate's commitment. o In 2004, the J. Epstein Foundation contributed a total of $162,610 in educational scholarships to All Saints Cathedral School, Antilles School, the Community Foundation of the VI Inc. and the Ruby Rutnik Scholarship Fund. A total of $95,866 in charitable contributions were made to some charities which included; Dinn Bra Page 15 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022912 EFTA02808255 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 17 of 19 - UNITED STATES VIRGIN ISLANDS Tgeotatens Virecus f/b/o Yankees Pee Wee Team, Humane Society of St. Ras Tafari Improvement Association, Inc., the Virgin M.Golf Federation, Inc. and the Women's Coalition of St. Croix. A contribution of $5,000 was made to an Educational Symposium. These contributions were $226,476 over the certificate's commitment. o In 2005 contributions from the J. Epstein Foundation Fund to Educational Scholarships totaled $90,200. These were given to All Saints Cathedral School, Alpha Kappa Alpha Sorority, Inc., Antilles School, Julius E. Sprauve, Miss. Virgin Islands Scholarship Fund and the Ruby Rutnik Scholarship Fund, Inc. A total of $138,019 was given to charities which included UVI Upward Bound Parent Association, Caribbean Chorale, Inc., BAPO Softball League and Catholic Charities of the Virgin Islands. An additional contribution of $20,595 was made to an Educational Symposium on Physics. o In 2006, the J. Epstein Foundation made charitable contributions totaling $43,776 to The St. 1.1 Storm Baseball Club, the United Way of St. 11. -St. John, e Community Foundation of the Virgin Islands. Educational scholarships totaling $115,590 was given to The Friends of the St. Min Public Library, Miss. Virgin Islands Scholarship, All Saints edral School, Antilles School and Interscholastic Athletic Association. The J. Epstein Foundation hosted the CERCA Physics Conference and contributed a total of $260,971. It is noted that during the period covered in this report, Financial Trust Company, Inc. ($7,000) and the J. Epstein Foundation ($14,300) made contributions totaling $21,300 to organizations not qualified to receive tax-deductible contributions in rite with the Internal Revenue Service. These organizations include the St St. John Chamber of Commerce, the 2004 Congressional Campaign Committee, People for Progress, the Governor's Special Events Fund and the Dejongh Francis 2006 Transition. Page 16 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022913 EFTA02808256 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 18 of 19 UNITED STATES VIRGIN ISLANDS TOWediterkt DMUS 5. The applicant shall utilize the services of resident licensed broker dealers whenever possible, given market conditions. • The Beneficiary provided documentation showing Seslia Securities, a FINRA registered broker was utilized as a Broker of Record for their Savings Incentive Match Plan. REPORTING REQUIREMENTS: MC Annual Report: Current Income Tax Return / Audited Financial Statements Current Lt. Governor's Annual Report: Current VIESA Report: Current Affidavit of 1DC Beneficiary: Current Publication Notices Current FINANCIAL ANALYSIS REVIEW: Cost Benefit Analysis reflects an approximate ratio of 1 to .21 for the years 1999 to 2006. This means that for every $1 given up in tax benefits $0.21 was spent in the local economy which includes employee taxes paid, local wages, local taxes paid, local procurement of goods and services and capital expenditures, a loss of $0.79. This includes the value of tax exemptions on personal income tax of Mr. Jeffrey Epstein, the sole owner of Financial Trust Company, Inc. Page 17 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022914 EFTA02808257 Case 1:22-cv-10904-JSR Document 186-39 Filed 06/14/23 Page 19 of 19 UNITED STATES VIRGIN ISLANDS %weans neat CONCLUSION 1. Met the investment requirement. 2. Met the full-time employment requirement. 3. Met the residency and management requirement 4. Complied with the procurement requirements. 5. Complied with Special Condition #1 by providing Health, Life and Dental Insurance funded by the Beneficiary. 6. Complied with Special Condition #2 by providing a qualified retirement plan funded by the Beneficiary. 7. Complied with Special Condition #3 by providing training and tuition reimbursement to eligible employees. 8. Did not specifically comply with Special Condition #4 - annual charitable contributions in 2005 and 2006. There was a shortfall of $12,500 for Co-op Marketing with the EDC and $42,322 to charity and educational scholarships. However, contributions made from the J. Epstein Foundation for charity and educational scholarships exceeded the overall requirement 9. Complied with Special Condition #5 by utilizing resident licensed broker dealers. 10.Complied with the reporting requirements of the EDC. Prepared by: Sandra Bess Reviewed by: Margarita A. Greenidge April 14, 2008 Page 18 CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER VI-JPM-000022915 EFTA02808258