Type of Report Financial Crimes E aforcement Network United Seaes Deparument of the Tres |) FinC EN BSAR Transcript BSA: 31000150416250 and DCN: Initial Report Filing Information Filing Date 07/13/2019 Received Date 07/13/2019 Entry Date 07/15/2019 0SZ9L¥V0S LOOOLE -vSd Submission Method Electronic discrete filing Subject Information EPSTEIN Role ject 1 of 3 Subject Subject Type Purchaser/Sender Individual/Organization Individual Last(or Entity) Name EPSTEIN First Name Gender Type JEFFREY Male Date of Birth SSN/ITIN Form(s) of Identification Identification Type Identification Number c a) ” & o QZ oS a Issuing Country Code Address(es) Address Type | Subject permanent/mailing address Street Address City State ZIP Code Country Phone Number(s) Type | Work Number Email(s) Occupation/Type of Business Executive/Southern Trust Co. Corroborative Statement to Filer No Relationship to Financial Institution TIN | EFTA00151545

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)) FinCEN ‘inancial Crimes Enforcement Network ited Seaes Departement of the Tre BSAR Transcript BSA: 31000150416250 and DCN: Subject Information Institution(s) Affected Account(s) Relationship of Subject Account Number Customer: Yes Financial Institution TIN Subject 2 of 3: KAHN Role | Subject Subject Type | Purchaser/Sender Individual/Organizati Last(or Entity) First Gender Type | Male — Form(s) of Identification Identification Type Identification Num Issuing Country Code Passport Address(es) | Address 1 of 3 Address Type NEW YORK - Enhanced State NY NY - Enhanced ZIP Code 10021-3241 10021-3241 - Enhanced Country US US - Enhanced Address 2 of 3 Address Type NEW YORK - Enhanced State NY ZIP Code NY - Enhanced 10022-6146 10010-5516 - Enhanced Page 2 EFTA00151546 0SZ9L¥0SLOOOLE -vSd

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0SZ9LvO0SLOOOLE -VSd Occupation/Type of Bu Relationship to Fi Instit Affected Accq Subject 3 of 3 : SOUTH._ _ Role | Subject EFTA00151547

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Financial Crimes Enforcement Network United Seates Department of the Treasury )) FinCEN BSAR Transcript BSA: 31000150416250 and DCN: Subject Information Issuing Country Code | VI Address(es) Address Type | Subject permanent/mailing address Street Address 0SZ9LV0S LOOOLE -vSd City State ey So S w > roy ZIP Code 00802-1348 - Enhanced Country NAICS Code | 5221 NAICS Code Text | Depository Credit Intermediation Phone Number(s) Type | Work Number | | Relationship to Financial Institution TIN | | Institution(s) |" Relationship of Subject | Customer. Yes | Affected Account(s) Account Number | | Financial Institution TIN | | Suspicious Activity Information Amount Involved | $27,658,324 Date or Date Range of Activity | 06/28/2019 - 07/10/2019 Money laundering | Suspicious EFT/wire transfers Financial instrument or | Funds transfer payment mechanism | Foreign currency Activity Location Financial Institution Location 1 of 1 No Branch Activity Involved | Yes Type of Financial Institution Securities/Futures | Subsidiary of financial/bank holding company Clearing broker-securities Primary Regulator | SEC RSSD Number | Legal Name | Charles Schwab & Co., Inc ot __| Address Address Type | Address where transaction occurred teminated under provisions of EFTA00151548

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FinCEN 0SZ91LvO0SLOOOLE -VSd BSAR Transcript BSA: 31000150416250 and DCN: Activity Location Street Address | | ee PT | |_| a aa PT 7 | Internal Control File Number | CA111517 Filer Informatica Primar Type of Financial RSg Internal control/ Contact for 4 Law Enforcem No Law Enforcement Information Available Page 5 EFTA00151549

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\ Fi CEN Financial Crimes Enforcement Network inU United Seates Department of the Tressury BSAR Transcript BSA: 31000150416250 and DCN: Narrative This SAR is being filed by The Charles Schwab Corporation on behalf of Charles Schwab & Co., Inc. ("Schwab"), a registered broker dealer, to report concerns with attempted wires for the purpose of real estate, in light of negative media surrounding Jeffrey Epstein. The concern relates to an upcoming bail hearing for Mr. Epstein and stated concern regarding Jeffrey Epstein being a possible flight risk. This investigation is the result of an internal referral. Please refer to internal number CA111517 when requesting more information regarding this report. The three subjects of this SAR are: Southern Trust Company LLC who established a relationship with Schwab in April 2019 consisting of an active corporate brokerage account, EE. The company is registered in the United States (U.S.) Virgin Islands, license number GE as a business and management consulting firm, and was established in December 2018. Jeffrey Epstein (66 years old) established a relationship with Schwab in April 2019 and acts as an internal control person and beneficial owner on three accounts; the role does not grant him authority to act upon the Schwab accounts. Jeffrey Epstein is included as a subject of this SAR due to the negative media involving recent Federal charges. His disclosed employer is Executive at Southern Trust Company Inc. HE (46 years old) established a relationship with Schwab in April 2019 consisting of three active corporate accounts. His disclosed employment is Senior Executive at HBRK Associates Inc. EJ appears to be a close business partner in various ventures with Jeffrey Epstein, including Southern Trust Company. The outgoing wires of concern were identified in the Schwab corporate brokerage account [EE registered to Southern Trust Company, Inc. [MM is the authorized agent, providing him the authority to act upon the account, and Jeffrey Epstein is listed as an internal control person and 100 percent beneficial owner; Mr. Epstein does not have any authority to act upon the account. accordingly. The ncluding ar f Financial C ansmitted without p ven that they contain unsubstantiated must b iminal activity, akin t ted under th EFTA00151550 0SZ9LV0S LOOOLE -vSd

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a {1 ) FinCEN Financial Crimes Enforcement Network United Seaes Departmen of the Tressury BSAR Transcript BSA: 31000150416250 and DCN: Narrative Schwab's investigation encompassed the time period ranging from 04/11/2019 to 07/10/2019. The activity in question occurred between 06/28/2019 and 07/10/2019, as referenced in Part Il, line 30 of this SAR. The dollar amount $27,658,324.00, referenced 0SZ9L¥0S LOOOLE -vSd in Part Il, line 29 of this SAR represents the total amount of outgoing wires of concern which were identified during the investigation period. Jeffrey Epstein was arrested and federally charged on 07/08/2019 with one count of sex trafficking of minors, and one count of conspiracy to engage in sex trafficking of minors; allegations indicate that the activity took place between 2002 and 2005, possibly with an exchange of funds for acts. Jeffrey Epstein is being held in jail, with a scheduled bail hearing on 07/15/2019. Prosecutors consider Jeffrey Epstein a very high flight risk given his enormous wealth, international ties, and private planes. With the recent federal charges and concerns of flight risk, Schwab identified concerns with outgoing wires identified within the account of concern around the time Jeffrey Epstein was arrested and charged. On 06/26/2019, Schwab received a request to send an international foreign currency wire, the request signed by both HEB and Jeffrey Epstein, from brokerage account I. The wire was requested for 11,150,000 Euros (EUR) or $12,708,324.00 (USD). The wire was remitted to Marc Leon located at Imm E| Pacha Hin Morocco. The funds were sent to an account at Bank Julius Baer and Co. Ltd. located in Zurich Switzerland, account rn Research regarding Marc Leon identified that he is a partner at Kensington Morocco; the firm offers luxury properties in Morocco and France (www.kensingtonmorocco.com). The following day, 06/27/2019, Schwab received a call from EE asking if it was possible to terminate the aforementioned wire. The Schwab representative asked the reason for the reversal request, and | explained the reason was “for a concentrated real estate transaction, and uh, what uh, terms we were told we had on uh an agreement, were uh, ¢ author jeritial informant tip EFTA00151551

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4 \ Fi CEN Financial Crimes Enforcement Network =) in 4 United Seaes Department of the Tressury BSAR Transcript BSA: 31000150416250 and DCN: Narrative not, were reneged on this morning. So uh, we are hoping it still can be a deal, but at this point the terms that | accepted are not agreeable, | want to retract the wire." 0SZ9LV0S LOOOLE -vSd The wire had been posted, and currency was exchanged. In order to reverse the wire, Schwab relayed to Mr. Kahn that it would be a "best effort" since the 30 minute window to cancel had lapsed. In the event Schwab was successful in reversing the wire, HER agreed to assume any losses, but alluded that if there was a gain, he hoped he would receive the profit. Schwab was able to successfully retract the wire posted on 06/26/2019, and realized a ($113,527.80) loss after the currency conversion. The funds have been deposited back into brokerage account EB registered as Southern Trust Company, Inc., on 07/10/2019. indicated the wire for 11,150,000 Euro was sent prematurely, but that he may need to send another wire for even more to a different escrow account. This information was relayed during the conversations regarding the reversal request. On 07/04/2019, Schwab received a second international wire request, again signed by both EEE and Jeffrey Epstein; the request was to send $14,950,000 USD to Marc Leon located at Imm E! Dacha Morocco. The funds were sent to an account at Bank Julius Baer and Co. LTD located in Zurich Switzerland, reflecting an updated account number (At the time of this request, the account did not have a balance to support the wire request as the retracted wire was still pending deposit back to account [E- GR sent an email to Schwab five days later on 07/09/2019, asking to "please cancel this wire.” Once the retracted wire was posted to account {EE on 07/10/2019, Schwab made an outbound call to EJ where he confirmed he did not want the $14,950,000.00 wire to be processed. In addition, IEEE asked the Schwab representative if future wire requests would require two signatures (note at this time Jeffrey Epstein was in jail). He indicated he would need to send more wires out soon. Please see the attached CSV for detailed information pertaining to the outgoing wires. ve enclosed information oecter eminated under provisions of the EFTA00151552

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FinCEN Financial Crimes Enforcement Network United Seaes Department of the Tressury BSAR Transcript BSA: 31000150416250 and DCN: Narrative As of 07/10/2019, there have not been any funds remitted from the three accounts associated to [J and Jeffrey Epstein, each established at Schwab in April 2019. 0SZ9LV0S LOOOLE -vSd The transactional review of these accounts discovered the accounts were funded by wire deposits and transfers of assets (TOA) from other financial institutions. Deposited funds were ultimately transferred to brokerage account {EE at Schwab. The three associated accounts were each initially funded with a $250,000.00 check deposit remitted from Deutsche Bank Trust or FirstBank accounts. The accounts they were transferred from were like-registered. Account J received a $2,000,000.00 wire from an external like-registered account to Southern Trust Company. In addition, brokerage account [EE registered to Southern Financial LLC received a wire deposit from Southern Trust Financial LLC ($2,000,000.00) and check deposits from Coatue Enterprises LLC ($39,800.00), and Darren Indyke & Michelle Saipher ($42,700.00). The memo on the check deposits noted promissory interest payments. The three accounts also received incoming investment account transfers from like registered accounts at TD Ameritrade and Merrill Lynch. As of 07/10/2019, various investments have been sold and the majority of proceeds have been transferred into brokerage account EE used to fund the attempted outgoing wires. Schwab determined to file this SAR reporting concerns with international wires attempted to be remitted to an individual in Morocco for real estate purposes. In light of the negative media surrounding Jeffrey Epstein, including the upcoming bail hearing, Schwab is filing to report attempted money movement for an individual considered a flight risk. Schwab maintains all supporting documentation. Written requests for supporting documentation may be sent to HE. lease refer to internal number CA111517 when requesting more information regarding this report. The enclosed inf secordingly. The ncluding ar { Financial C Enforcement gations of possible criminal activity, akin t 5311, et seq.; 31.C tigation of pr must b ted under th ven that they contain unsubstantiated EFTA00151553