9100 PORT OF SALE MALL PHONE (340) 779.2564 SUITE 15 FAX (888) 316.9269 KELLERHALS FERGUSON FLETCHER KROBLIN LLP ST. THOMAS, Vi 00802-3602 KFFKLAW.COM December 2, 2013 Via Hand Delivery Mr. John McDonald Director Office of the Lieutenant Governor Division of Banking & Insurance 5049 Kongens Gade St. Thomas, VI 00802 Re: — Financial Strat roup, Ltd. IBE Application Supplement Dear Director McDonald: This correspondence shall serve as a supplement to the initial application for benefits under the International Banking Entity Act filed by Financial Strategy Group, Ltd. in January 2013. As requested in your email correspondence with Mrs. Cecile deJongh, we are providing the following: Updated Due Diligence Disclosure Affidavit for Mr. Jeffrey Epstein; Management Organization Chart List of Jurisdictions Check in the amount of $10,000.00. See Kindly advise us if you need any additional information. Very truly yours, Erika Kellerhals enc, TAMPA | US VIRGIN ISLANDS | NEW YORK EFTA00306116

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Due Diligence Disclosure Affidavit EFTA00306117

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Management Organization Chart Upon formation, Mr. Epstein shall serve as the President and CEO of the company. It is anticipated that the initial employment needs of the company can be met with the initial hiring of an administrative person and a financial/tax analyst with experience in one or more of the following sectors: reinsurance, private equity, bank advisory, and life sciences. FSG has requested a waiver of the additional hiring requirement, but anticipates that as it grows, management personnel will be hired to oversee each line of business. Both the administrative assistant and the analyst would report directly to Mr. Epstein. EFTA00306118

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List of Jurisdictions FSG will be headquartered in the U.S. Virgin Islands. It is not anticipating having offices in any other jurisdiction, but will notify the Division of Banking & Insurance in the event that changes. Furthermore, FSG does not anticipate owning property outside the U.S. Virgin Islands. FSG may conduct business in the United States and in non-US jurisdictions. EFTA00306119