Financial Crimes Enforcement Network United Seates Department of the Treasury )) FinCEN BSAR Transcript BSA: 31000150840679 and DCN: Filing Information Type of Report | Initial Report Filing Date | 07/19/2019 Received Date | 07/19/2019 Entry Date | 07/22/2019 Submission Method | Electronic batch filing Subject Information Role | Subject Subject Type | Purchaser/Sender 62907805 LOOOLE -vSd Individual/Organization | Individual Last(or Entity) Name | EPSTEIN First Name | JEFFREY Middle Name | E Gender Type | Male Date of Birth | | SSN/ITIN Form(s) of Identification | Identification 1 of 2 Identification Type | Driver's license/State ID Identification Number Issuing State Code | VI Issuing State | Virgin Islands, U.S. Issuing Country Code | VI Identification 2 of 2 Identification Type | Passport Identification Number | Issuing Country Code | US Address(es) | Address 1 of 2 Address Type | Subject permanent/mailing address Street Address eminated under provisions of EFTA00151554

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Financial Crimes Enforcement Network United Seates Departmenc of the Tressury )) FinCEN BSAR Transcript BSA: 31000150840679 and DCN: Subject Information 00802 - Enhanced Country | VI US - Enhanced 62907805 LOOOLE -vSd Address 2 of 2 Address Type | Subject permanent/mailing address Street Addresff s Country US - Enhanced Phone Number(s) | Phone Number 1 of 2 Type | Work Number Phone Number 2 of 2 Type | Residence Number Occupation/Type of Business | INVESTMENT BUSINESS CONSULTAN Corroborative Statement to | No Filer Relationship to Reporting Institution TIN Institution(s) Relationship of Subject | Customer. Yes Affected Account(s) | Account 1 of 6 Account Number Financial Institution TIN Account 2 of 6 Account Number Financial Institution TIN Account 3 of 6 Account Number Financial Institution TIN Account 4 of 6 Account Number EFTA00151555

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Enforcement Network United Seates Deparument of ¢ resury )FinCEN BSAR Transcript BSA: 31000150840679 and DCN: Subject Information Financial Institution TIN | [i Account 5 of 6 Account Number | | Financial Institution TIN | | Account 6 of 6 Account Number | | 62907805 LOOOLE -vSd Financial Institution TIN | Subject 2 of 4: F T REAL ESTATE INC Role | Subject Subject Type | Payee/Receiver Individual/Organization | Organization Last(or Entity) Name | F T REAL ESTATE INC EIN | 660695228 Address(es) | Address 1 of 3 Address Type | Subject permanent/mailing address Street Address s Country US - Enhanced Address 2 of 3 Address Type | Subject permanent/mailing address Street Address s Country US - Enhanced Page 3 EFTA00151556

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)) FinCEN United Seaes Departmens of the Tressury BSAR Transcript BSA: 31000150840679 and DCN: Financial Crimes Enforcement Network Subject Information Address 3 of 3 Address Type Subject permanent/mailing address Street Address 62907805 LOOOLE -vSd Country s US - Enhanced NAICS Code 530000 Phone Number(s) Phone Number 1 of 2 Type Facsimile Number Phone Number 2 of 2 Type Work Number Occupation/Type of Business Relationship to Reporting Institution(s) REAL ESTATE RENTAL LEASING Institution TIN Relationship of Subject Customer: Yes Affected Account(s) Role Account 1 of 2 Account Number Financial Institution TIN Account 2 of 2 Account Number Financial Institution TIN Subject Subject 3 of 4: LAUREL INC Subject Type Purchaser/Sender Individual/Organization Organization Last(or Entity) Name LAUREL INC EIN 660776877 Form(s) of Identification Identification Type | Driver's license/State ID Address(es) Address 1 of 2 Address Type | Subject permanent/mailing address Page 4 ct (the ¢ informa ay be x 7 cluding analy tect against internat EFTA00151557

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Subject Information ZEN Financial Crimes Enforcement Network United Seates Deparument of the Tressury BSAR Transcript BSA: 31000150840679 and DCN: NAICS Code Phone Number(s) 62907805 LOOOLE -vSd Street Address | [as PTT 2 oe Li | | mz a | Country | VI US - Enhanced Address 2 of 2 Address Type | Subject permanent/mailing address Street Address | a’ PO | | |__| me i |_| Country | VI US - Enhanced 561110 Phone Number 1 of 2 Type | Residence Number | a Phone Number 2 of 2 Type | Work Number | a Occupation/Type of Business Office Administrative Services Relationship to Reporting Institution(s) Institution TIN Affected Account(s) Relationship of Subject | Customer. Yes Account 1 of 2 Account Number | Financial Institution TIN | Account 2 of 2 Account Number | Page 5 EFTA00151558

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JF inCEN Enforcement Network United Seate ztment of the Tressury BSAR Transcript BSA: 31000150840679 and DCN: Subject Information Subject 4 of 4: MICHELLES T Role Financial Institution TIN RANSPORTATION COMPANY LLC Subject Subject Type Payee/Receiver 62907805 LOOOLE -vSd Individual/Organization Last(or Entity) Name EIN Address(es) Organization MICHELLES TRANSPORTATION COMPANY LLC | Address 1 of 2 Address Type Subject permanent/mailing address Street Address Country c|< ” m J s o 3 o om Qa Address 2 of 2 Address Type Street Address Subject permanent/mailing address Country s US - Enhanced NAICS Code 483114 Phone Number(s) Phone Number 1 of 2 Type Number = » ° 2. 3. > Phone Number 2 of 2 Type Work Page 6 EFTA00151559

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Financial Crimes Enforcement Network United Seaes Departments of the Tressury Institution(s) fee) wn BSAR Transcript pa BSA: 31000150840679 and DCN: * Subject Information = Number | la Occupation/Type of Business | WATER TRANSPORTATION @ Relationship to Reporting Institution TIN | =} g wo Relationship of Subject | Customer. Yes Affected Account(s) | Account 1 of 2 Account Number Financial Institution TIN Account 2 of 2 Account Number Financial Institution TIN Suspicious Activity Information Amount Involved | $1,740,000 Date or Date Range of Activity | 06/25/2018 - 03/29/2019 Money laundering | Suspicious EFT/wire transfers Suspicious concerning the source of funds Suspicious use of multiple accounts Transaction out of pattern for customer(s) Other suspicious activities | Transaction with no apparent economic, business, or lawful purpose Financial instrument or | Funds transfer payment mechanism Activity Location Financial Institution Location 1 of 1 No Branch Activity Involved | Yes Type of Financial Institution Depository institution | Primary Regulator | FDIC RSSD Number | Legal Name | FIRSTBANK PUERTO RICO EN | Address Address Type | Address where transaction occurred Street Addresi] | as PO oa | |_| | | a a EFTA00151560

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Financial Crimes Enforcement Network United Seates Department of the Treasury |) FinCEN BSAR Transcript BSA: 31000150840679 and DCN: Activity Location Country | PR US - Enhanced Internal Control File Number | 2019-05-000722-000 62907805 LOOOLE -vSd Filer Information Primary Regulator | FDIC Filer Name | FIRSTBANK PUERTO RICO EN | Address Address Type | Reporting party address Street Address | PO Ss {| = a | ee |__| Country | PR US - Enhanced Type of Financial Institution Depository institution RSSD Number | Internal control/file number | 2019-05-000722-000 Contact for Assistance Full Name | COMPLIANCE Phone Number | (787) 993-5150 Phone Type | Work Law Enforcement Information No Law Enforcement Information Available Narrative Our Compliance Department received a referral to verify the existence of any suspicious activity being perpetrated against customer Laurel Inc. The customer was referred by our ASSIST Monitoring Unit after performing the Daily Newspaper Review and noticing negative news regards the customer authorized signers (sex offenders). This revision covers the transactions processed from May 1, 2018 to June 9, 2019. The customer maintains twenty-five (25) accounts relationship with FirstBank which are listed EFTA00151561

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) FinCEN Financial Crimes Enforcement Network United Seates Department of the Treasury BSAR Transcript BSA: 31000150840679 and DCN: Narrative on Exhibit-A. Due to the extension of the customer relationship and the type of referral (signers related to sex offenders found on negative news) this case will be divided on three (3) separate cases, 2019-05-000717; 2019-05-00720 and the present case under 2019-05-000722. Which analyzed eight (8) accounts for the customer relationship. The accounts evaluated under this case 62907805 LOOOLE -vSd were opened at our FirstBank Plaza (721), East End Plaza (717) and Waterfront (719) all branches located at USVI.Laurel IncJ Epstein Virgin Island foundation Inc (T/A Enhance Education). The Jeffrey Epstein VI Foundation is a private science foundation at Harvard University with a $30 million gift to the university. The Program for Evolutionary Dynamics is considered the first department of its kind to study the evolution of molecular biology with the sole use of mathematics. The Jeffrey Epstein VI Foundation is also known for giving one of the largest amounts of funding to individual scientists around the world.IGO Company LLC (American Yacht Harbor).Jeepers Inc.F T Real Estate inc. Thomas World Air LLC.Michelles Transportation Co LLC;As per information in our system applications and data bases, the individuals or entity hold no banking relationships in our FirstBank Florida and/or Puerto Rico regions.We conducted a search on the internet and to validate any negative news, information, or articles for the customer and various articles with negative information were found; (i) Daily Beast, April 16, 2019. Billionaire Pedophile Jeffrey Epstein Secret Charity (ii) New York Post, May 9, 2019, Billionaire pedophile Jeffrey Epstein illegally building Virgin Islands compound; (iii) New York Post, October 9, 2016, The sex slave scandal that exposed pedophile billionaire Jeffrey Epstein (iv) Opensecrets news; December 4, 2018, Billionaire sex offender Epstein gave heavily to democrats, until he did not; among others.According to the referral documents two (2) suspicious incoming wire transfers were processed in customer account I for which we were not able to establish purpose; service rendered. As per the referral the first suspicious transaction was processed on October 24, 2017 for $225,000.00 and the second transaction was processed on September 28, 2018 for $180,000.00. The total suspicious amount for this referral was $405.000.00. In addition was included negative news/ information regards our customer for sex offender and bad news found.We reviewed our customer accounts relationship to validate any suspicious activity and following are the observations.Commercial checking account{{EEEEEINo cash or check deposit was processed; three (3) incoming funds wire transfers were processed for $580,000.00. These transactions were processed from September 28, 2018 to March 29, 2019 and all the transactions were originated by HBRK ASSOCIATES, INC. We performed an internet search for this company and was found that the NAIC code assigned (541990) was defined as all other professional, scientific and technical services; however we were not able to find the exact line of business for the company.One (1) check was negotiated for $300.00 payable to Government of the USVI and one (1) Automated Clearing House (ACH ) debit for Enforcement Network or his authori. ntain unsubstantiated allegabons of possible criminal activity, akin to confidential informa vil sanctions t must be trea! Wlected under the BSA ma EFTA00151562

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| FinCEN Financial Crimes Enforcement Network United Seaes Department of the Tressury BSAR Transcript BSA: 31000150840679 and DCN: Narrative $196,673.56 payable to Palm Beach Tax.Commercial checking account{EENo cash or check deposit was processed; two (2) ACH credits were processed for $0.23 and three (3) incoming funds wire transfers totaling $298,626.14 issued by J EpsteinVirgin Island Foundation (account at The Bank of New York Mellon the reference include in the transaction was Pershing 6290780S LOOOLE -vSd LLC) and from Education Advance ($50,000.00) (account at JP Morgan Chase; the reference included was returned donation. No other detail was available.Nineteen (19) checks were negotiated totaling $212,494.54. The highest check amount processed was for $50,000.00 to National Crime Victor Bar Association. Other checks processed were payable to Edge Foundation Inc, Joshua Bach, (SJE Lc, American Express, Travelers among others. Two (2) outgoing funds wire transfer was processed for $13,535.99 both transactions payable to Peninsula Property Management located at 521 Harbor City Boulevard Melbourne Florida USA; as per the instructions included were rent payments.Commercial checking account 7171030625; 7171030636As per our evaluation no alert or suspicious activity was observed in the review period. The transactions processed in the period are available on file-Commercial checking account 7171030966No cash or check deposit was processed; one (1) ACH credit was observed for $18,500.00 issued by Alpha Group Capital and two (2) incoming funds wire transfers were processed for $840,000.00. According to our system applications both transactions were originated by David J. Mitchell with address at HE SA. No instructions or details were included. We performed a search on internet and was found a possible match with David J. Mitchell; Chief Executive Officer and President of CenterPoint Corp. since January 24, 2002 and performs policy making functions. Mr. Mitchell has been a partner of Petherton Capital Corporation since March 1992. He founded Mitchell and Company, Ltd., in January 1991 and has been its President since its inception. He has been Managing Partner of Las Vegas Land Partners LLC since June 2004. In 2004, he became Managing Members of MandM Advisors LLC. The listed corporation address is at [i (2) ACH debits were processed for $524.00 payable to New York State Department of Finance. Also one (1) outgoing funds wire transfer was processed for $75,000.00 payable to VIBT Inc. The transaction was identified as a donation. The company address is at [ES and was organized as a promotion of international understanding; promotion of grow and development of commerce and industry in the USVI.One (1) debit memo was processed for $25,015.00 as per our applications was these funds were a charitable donation to VIBT Inc (through the purchase of manager check 5304 on October 1, 2018). According to information found in internet VIBT Incis an organization that promotes international understanding through activities, such as events, forums, trainings, and exchanges.and one (1) check was negotiated for $300.00 payable to Government of USVI.Commercial checking account author 25. jeritial informant tip EFTA00151563

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Financial Crimes Enforcement Network United Seates Deparunenc of the Treasury ) FinCEN BSAR Transcript BSA: 31000150840679 and DCN: Narrative 71710403050ne (1) funds transfer credit was processed for $175.01 (interest accrued on customer certificate of deposits 7178105695) and one (1) incoming funds wire transfer was processed for $200,000.00 originated by Jeffrey Epstein care of HBRK Associates Inc; the instruction included was fund account.One (1) debit memo was processed for $500.00 as per our applications was to issue a letter of credit and fifty-six (56) checks were processed totaling $70,078.98. The highest check amount processed was for $3,846.00, this check and the majority of the checks processed were payable to Virgin Island Port Authority. Other checks processed were payable to Virgin Island Water and Power Authority, Government of the USVI, Reefco Services Inc, TRI Island Energy LLC among others.Certificate of deposit 7178105695No credit or debits were processed in this certificate in the review period.Commercial checking account 7191415759No cash deposit was processed.One (1) check deposit was observed for $1,167.22 issued by AIG Property Casualty Company. Three (3) incoming funds wire transfers were processed totaling $320,000.00; all the three (3) transactions were issued by HBRK ASSOCIATES, INC; no information regards purpose or service rendered was included.Five (5) checks were negotiated totaling $19,996.26. The highest check processed was for $10,537.00 payable to Insurance Office of Central Ohio. The remaining checks processed were payable to Lee Thomas and Government of the USVI.No Currency Transaction Report (CTR) was filed; none of the cash transactions processed reached or surpassed the required threshold.After reviewing this case and analyzing all the available facts we can classify this case positive. Unusual incoming funds wire transfers were processed in our customer accounts (E: EE end EE for which were not able to validate the purpose or service rendered for the issuance of these transactions. In addition no relevant information was found on our search on internet that help us validate the purpose; line of business of the issuer.For the above reasons, we will file a Suspicious Activity Report (SAR) totaling $1,740,000.00 for customer accounts A: and (EM. The period on which the suspicious activity was processed was from June 25, 2018 to March 29, 2019.Supporting Documents: Image Centre; Assist; Mainframe; Internet; OneSum<x, etc. transmitted wit cr ut p ¢ autho onfiderttial inforrnat ven that they contain u SA may result in criminal or civil sanctions. must b ted under th EFTA001 6290780S LOOOLE -vSd 51564