OFFICIAL RECORD

• OFFICIAL RECORD FD-1057 (12cv. 543-10) UNCLASSIFIED FEDERAL BUREAU OF INVESTIGATION Electronic Communication Title: (U) Request case opening Date: 04/29/2020 From: SAN JUAN Contact: Approved By: SSRA Drafted By: Case ID #: 196D-SJ-3262541 (U) SOUTHERN TRUST; SOUTHERN COUNTRY INTERNATIONAL; Wire Fraud Synopsis: (U) To open an investigation into the transfer of $15,000,000 by Jeffrey Esptain after his death on 8/10/2019 into his defunct SOUTHERN COUNTRY INTERNATIONAL bank located in the US Virgin Islands. Details: FINANCIAL STRATEGY GROUP, LTD (FSG) submitted an application for a banking business license in the United States Virgin Islands through local attorney ERIKA KELLERHALS on 03/21/2013. JEFFREY EPSTEIN, DARREN INDYKE, and RICHARD KAHN were listed as the officers of the business with a $100,000 value at initial opening. The originally FINANCIAL STRATEGY GROUP, LTD maintained office space in the Port of Sale Mall in Havensite, but in 2015, FSG was renamed SOUTHERN COUNTRY INTERNATIONAL, LTD and designated as an International Banking Entity with a new address, , St. Thomas, VI 00802. The Lieutenant Governor's Office, Division of Banking, Insurance, and Financial Regulations issued the business license to SOUTHERN COUNTRY authorizing the bank to conduct business in the Virgin Islands beginning in 2015. EPSTEIN uses the above address for several companies licensed in the Virgin Islands. Many of these companies qualify for Economic Development UNCLASSIFIED EFTA00128637 UNCLASSIFIED Title: (U) Request case opening Re: 196D-SJ-3262541, 04/29/2020 Company status which allows the company to defer many of the business tax liability in exchange for creating jobs in the Virgin Islands. The address is a yachting marina dock space with no physical banking space. On July 06, 2019, EPSTEIN was arrested in New York City on a matter unrelated to this bank. While in custody pending trial, EPSTEIN re-wrote his will and created a new trust. He left INDYKE, KAHN, and BORIS NIKOLIC as Executors of the will. On Aug 10, 2019, EPSTEIN committed suicide in the Bureau of Prison Metropolitan Corrections Center (MCC). On the day after his suicide, a bank transfer in the amount of $15 million dollars was moved from an EPSTEIN account at the DEUTSCHE BANK in New York and arrived at SOUTHERN COUNTRY. This case will be jointly investigated by the FBI and the Internal Revenue Service - Criminal Investigations Division. District of the Virgin Islands AUSA agrees with opening an investigation into possible violations of 18 USC 1032, Concealment of assets from conservator, receiver, or liquidating agent. ♦♦ UNCLASSIFIED 2 EFTA00128638