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EFTA01480623

Dataset 10 · 1 page · 422 KB · 499 words

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EFTA01480623_p1_xref_8.jpg
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Tickete                105258603           Account%                                     Initiated Date        07/1312013 07:22
AM
Chem Name              HBRK                Account Title                                Initiator             JUSTIN D NELSON
ASSOCIATES INC
ECI                                        Account Type                                 Initiating Team       PS FRONT OFFICE
LOB                    PB
Verify & Confirm for HBRK ASSOCIATES INC
Final Risk Rating                          High
Initial Risk Rating                        Standard
GCS Report Requested                       Full
Presence of Potential High Risk            Yes
Indicators
Reason for Adjustment                      Reputations! - Convicted Felon
Comments
Summary of Risk Attributes                Jeffrey Epstein was convicted of a felony charge in 2008. Jos Staley conferred with
Stephen Cutler and the decision was made to keep Mr. Epstein as a PB ckent. Mr.
Epstein completed his sentence and probation in 2010.
Please summarize any material changes Jeffrey Epstein is an existing client of PB. He is an active brokerage client across asset
which have occurred with the client   classes currently covered by the Firm's 010 desk. Jeffrey Epstein has been an
within the past 12 months:            investment advisor for numerous high net worth clients and also a personal investor.
Jeffrey is very accessible and well known to the team. We have advised him on
investments as well as estate planning opportunities. Jeffrey has continues to be well
connected across business channels.
Epstein is well known to several JPM PS employees and senior management including
Jes Staley. Also. Mr. Epstein was convicted of a felony charge in 2008. Jes Staley
conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB
client. Mr. Epstein completed his sentence and embalm in 2010. The relationship has
been reviewed with senior management and compliance/legal on a few occasions over
the post year as news stories of Jeffrey's past are picked up. No new claims or stones
have surfaced recently.
Risk Updated History
Creation        Entered by                        Updated         Previous         Comment
Date                                              Risk            Risk
GCS Grid
Search Type                                Security Service Details                     Further Review Required
Company Information                        Information confirmed; details included in   No
the attachment.
Corporate Records                          Information confirmed: details included in   No
the attachment.
Other Database Searches                    No records were found.                       No
(RDC/MtS/Factiva)
Internal Database Search (CSSS/FPS)        Internal database search revealed prior    No
GS8I research for Harry Boiler and nothing
derogatory to report.
State Court Searches                       No records were found.                       No
Federal Court Searches                     No records were found.                       No
Personal Particulars                       Information confirmed; details included in   No
the attachment.
Publications                               Publications revealed nothing derogatory.    No
Regulatory Sanctions                       No records were found.                       No
OFAC/Control List Search                   A search of OFAC did not reveal any          No
matches
Negative cc Inconsistent Information                                                    No
Banker Attestation Details
As the client sponsor, I understand that I am primarily
responsible for protecting the fine'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 I • eta - • ulat• stand• • Int.
Please state your rationale for conducting business with this We are exiting HBRK and the Epstein relationship.
client
Comments
Confidential Treatment Requested by                                                                                                     JPM-SDNY-00002828
JPMorgan Chase
CONFIDENTIAL                                                                                                                            SDNY_GM_00272026
EFTA01480623
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