EFTA Document EFTA01582770

Tickers. Client Name ECU!. LOB. 102238622 ELLMAX 0033845033 P8 Acrou rila Account Title: Account Typo: Initialed Dates. Initialer: Initiating Team. 06222011 11:20 AM DEBRA WHITE PB FRCNT OFFICE Final Risk Rating Standard Initial Risk Rating Standard GCS Report Requested Full Presents of Potential High Risk Indicators No GCS Grid Search Type ___- Company Information Corporate Records Other Database Searches (ROOMS/Fatima) Internal Database Search (CSSSIFPS) State Coen Searches Federal Court Searches Personal Particulars Publications Regulatory Sanctions OFACControl Let Search Negative or Inconsistent Information lAecurityService Details ifurther Review Required Information not confirmed for alma (Tax ID). Details included Yos in the attachment Information contimiod; details included In the attachment. No records were found. Internal database search revealed prior GSI research and the following derogatory information was repelled, Several newspaper articles derailing the investigation conducted by Britain Serious Fraud Office against Robert Maxwell. He allegedly used pension funds to service debts, cover operating losses, Bantle in the foreign exchange markets. and support the stock of his publicly held companies The agency is also looking inlo a complaint from Swiss Bank Corp.. Much says it did not receive collateral for a $100 million loan to a small private Maxwell company. Newspaper article dated 12101!2000. which stated that Ch me Maxwells source of wealth is being classified as something of a my sleet Newspaper article dated 08109/1996 detailing the arrest of Ghislaine Maxwell on OW charges. Numerous newspaper articles derailing the criminal fraud charges brought against Kevin and Ian Maxwell (sons al Robert Maxwell). Newspaper article dated 6123(2005 detailing 'Robed Maxwell meappropnated funds from the companies under his control. According to the newspaper article. 'He pledged assets as securty for additional loans', but instead of ,delivenng the assets to the lender. he would simply sell the assets for cash. -For example. Bentz language school was supposedly sold to a Japanese publishing company, but the shares had previous H been pledged as security for loans from Swiss Volksbank and Lehman Brothers' .No records were found. No records were found. No additional research necessary. .No records were found. No records wore found. A search of OFAC did not reveal any matches. No No Yes No No No No No No Yes GCS Red Dot Confidential Treatment Requested by JPMorgan Chase JPM-SDNY-00062336 EFTA01582770