EFTA00151554.pdf

FinCEN I Financial Crimes Enforcement Network United Stain Departmatt alive Ticasury 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 Subject 1 of 4 EPSTEIN Role Subject Subject Type Purchaser/Sender 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 Page 1 The enclosed nfarmaticn was collected and disseminated under provisions of the Bank Secrecy Act Otte SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The reformation is sensitive ti nature and is to be treats accadingly. The information may be used only fa a purpose consistent with a crtnnal. tax. or regulatory five:ligation or proceeding. or in the conduct of ntelligence or counterntelligence activities. incluctn analysis, to protect against nternational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Enancial Crams Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA mutt be treated with particular care given that they contain unsubstantiated allegations of passable criminal activity. akin to confidential informant tips. Unauthorized release of information collected older the BSA may result in criminal or civil sanctions. 6L90V8051000LE:VS8 EFTA00151554 FinCEN Financial Crimes Enforcement Network United Surer Dept intent of the Treasury BSAR Transcript BSA: 31000150840679 and DCN: Subject Information 00802 - Enhanced Country VI US - Enhanced Address 2 of 2 Address Type Subject permanent/mailing address Street Addresi Country VI 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 Filer No Relationship to Reporting Institution(s) Institution TIN - Relationship of Subject Customer. Yes Affected Accounts) 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 Page 2 The enclosed nformatice was collected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regttations implementing the BSA. See 31 U S C. 5311, et sect .31 CFR Chapter X. The clot matron is sensitive n nature and is to be treats acceedingly. The information may be used only for a purpose conIntent with acrmna tax. or regulatory evestigatron or proceeding or in the conduct of ntelligence or counterntelligence activities. incluektg analysis, to protect against nternational terrorism. See 31 U S.C. 5311. The information carnet be further released, disseminated, disclosed. Of transmitted without prior approval of the Director of Financial Cremes Enforcement Network or his authorized delegate. Suspicious activity reports feed under the BSA must be treated with particular care green that they contain unsubstantiated allegations of paystale criminal activity, akin to confidential informant tips. Unauthorized release of information collected ruder the OSA may result in criminal or civil sanctions. 6L90V8091.0001£ VS9 EFTA00151555 FinCEN Financial Crimes Enforcement Network United Scan Dcps intent of the Timmy BSAR Transcript BSA: 31000150840679 and DCN: Subject Information Financial Institution TIN Account 5 of 6 Account Number Financial Institution TIN Account 6 of 6 Account Number Financial Institution TIN ct2•f4:FTaE'LEST4TEINC 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 II Country VI US - Enhanced Address 2 of 3 Address Type Subject permanent/mailing address Street Address Country VI US - Enhanced Page 3 The enclosed information was collected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Depxlment of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311. et seq.; 31 CFR Chapter X. The information is sensitive n nature and is lo be treated accordingly The information may be used only for a purpose con /attest' with a umiak tax, or regulatory rivestiganon of proceeding. or in the conduct of ntelligence or counterntelligence activities. includrig analysis, to protect against nternabortal terrorism. See 31 U.S.C. 5311. The information cannot be further released, disseminated, dixtosed. or transmitted without prior approval of the Director of Friancial Cranes Enforcement Network or his authorized delegate. Suspicious activity reports feted under the BSA must be treated with particular care given that they contain unsubstantiated allegation: of possable criminal actnity. akin to confidential informant tips. Unauthorized released information collected mule/ the BSA may result in criminal or civil sanctions. 6L90V805WOOLE VS9 EFTA00151556 FinCEN I Financial Crimes Enforcement Network Itai SCAM Department a the Ttaouty BSAR Transcript BSA: 31000150840679 and DCN: Subject Information Address 3 of 3 Address Type Subject permanent/mailing address Street Address Country VI 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 REAL ESTATE RENTAL LEASING Relationship to Reporting Institution(s) Institution TIN - Relationship of Subject Customer. Yes Affected Account(s) Subject 3 of 4 LAUREL INC Role Account 1 of 2 Account Number Financial Institution TIN Account 2 of 2 Account Number Financial Institution TIN Subject 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 I Subject permanent/mailing address Page 4 The enclosed nformatico was collected and disseminated under provisions of the Bank Secrecy Act (Me SSA) and U.S. Department of the Treasury reguLstions implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The nformation a sensitive n nature and is to be treats accadingly The information may be used only fa a purpose con ustent with a crtnnal. tax. or regulatory nvestigation or proceeding. or in the conduct of intelligence or counterntelligence activities. incluttlg analysis. to protect against ntemational terrorism. See 31 U S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without priors approval of the Director of Fnancial Crnes Enforcement Netwakon his authorized delegate. Suspicious activity reports filed under the GSA must be treated with particular care given that they contain unsubstantiated allegations of passtle criminal activity. akin to ccolldential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. 6L90V805[0001£ VS9 EFTA00151557 FinCEN Financial Crimes Enforcement Network UMW Sums Department tithe Ticouty BSAR Transcript BSA: 31000150840679 and DCN: Subject Information Street Address Country VI US - Enhanced Address 2 of 2 Address Type Subject permanent/mailing address Street Address 0 Country VI US - Enhanced NAICS Code 561110 Phone Number(s) Phone Number 1 of 2 Type Residence Number Phone Number 2 of 2 Type Work Number Occupation/Type of Business Office Administrative Services Relationship to Reporting Institution(s) Institution TIN Relationship of Subject Customer. Yes Affected Account(s) Account 1 of 2 Account Number Financial Institution TIN Account 2 of 2 Account Number Page The enclosed reformation was collected and disseminated under provisions of the Bank Secrecy Ad (the SSA) and U.S. Department of the Treasury regaattons implementing the BSA. See 31 U S C. 5311. et seg.. 31 CFR Chapter X, The Enloe mation is sensitroe n nature and is to be treats acccedingly. The information may be used only for a purpose consistent with a atonal tax. or regulatory nvestigatron or proceeding. or in the conduct of ntelligence or counterntelligence activities. incluckyg analysis, to protect against alternation,' terrorism. See 31 U.S.C. 5311. The information cannot be further released, disseminated, dixlosed, or transmitted without prior approval of the Director of FnancialCrames Enforcement Network or his authorized delegate. Suspicious activity reports feed under the BSA must be treated with particular care gwen that they contain unsubstantiated allegations of psyseble criminal actrnty. akin to confidential informant tips Unauthorized release of information collected wider the BSA may result in criminal or civil sanction:. 6L90V8051.00018.VSO EFTA00151558 FinCEN Financial Crimes Enforcement Network UMW States peps malt tithe lir:gouty BSAR Transcript BSA: 31000150840679 and DCN: Subject Information Financial Institution TIN Role Subject Subject Type Payee/Receiver Individual/Organization Organization Last(or Entity) Name MICHELLES TRANSPORTATION COMPANY LLC EIN Address(es) Address 1 of 2 Address Type Subject permanent/mailing address Street Address Country VI US - Enhanced Address 2 of 2 Address Type Subject permanent/mailing address Street Address M Country VI US - Enhanced NAICS Code 483114 Phone Number(s) Phone Number 1 of 2 Type Facsimile Number Phone Number 2 of 2 Type Work Page 6 The enclosed nfor malice was collected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regttations implementing the BSA. See 31 U S C. 5311. et seq.; 31 CFR Chapter X. The clot mation is sensitive n nature and is to be treats acccedingly. The information may be used only far a purpose con ustent with acrmna tax. or regulatory nvestigatron or proceeding. or in the conduct of ntelligence of counterntelligence activities. incluckig analysis, to protect against nternational terrorism. See 31 U S.C. 5311. The information cannot be further released, disseminated, dixlosed. Of transmitted without prior approval of the Director of Fnancial Crnses Enforcement Network or he authorized delegate. Suspicious activity reports feed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of pssuble criminal activity, akin to confidential informant tips. Unauthorized release of information collected Leder the USA may result in criminal or civil sanctions. 6L90V805WOOLE.VSO EFTA00151559 FinCEN Financial Crimes Enforcement Network Ualtoi Stain Dcpar omit of the nasuty BSAR Transcript BSA: 31000150840679 and DCN: Subject Information Number Occupation/Type of Business WATER TRANSPORTATION Relationship to Reporting Institution(s) Institution TIN 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 payment mechanism Funds transfer Activity Location Financial Institution Locatior 1 of 1 No Branch Activity Involved Yes Type of Financial Institution Depository institution Primary Regulator FDIC RSSD Number Legal Name FIRSTBANK PUERTO RICO EIN Address Address Type Address where transaction occurred Street Addresi Page 7 The enclosed nformatico was caected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury reguLations implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The nformation a sensitive n nature and is to be treated accadingly. The information may be used only for a purpose con ustent with a crtnnal. tax. or regulatory investigation or proceeding. or in the conduct of ntelligence or counterntelligence activities. inclueng analysis. to protect against nternational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Frnancial Crates Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passable criminal activity. akin to ccofidential informant tips. Unauthorized release of information collected wider the BSA may result in criminal or civil sanctions. 6L90V809[000IC VS8 EFTA00151560 FinCEN I Financial Crimes Enforcement Network United Soto De/paringlit of the ricbuty BSAR Transcript BSA: 31000150840679 and DCN: Activity Location Country PR US - Enhanced Internal Control File Number 2019-05-000722-000 Filer Information Primary Regulator FDIC Filer Name FIRSTBANK PUERTO RICO EIN Address Address Type Reporting party address Street Address 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 Page 8 The enclosed nformatico was caected and disseminated under provisions of the Bank Secrecy Act (Me SSA) and U.S. Department of the Treasury regttations implementing the BSA. See 31 U.S.C. 5311. et seq.: 31 CFR Chapter X. The nformation a sensitive ti nature and is to be treated accadingly. The information may be used only for a purpose consistent with acrmnal, tax. or regulatory nvestigation or proceeding. or in the conduct of ntelligence or counterntelligence activities. inclucran analysis. to protect against nternational terrorism. See 31 U.S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Palencia Crates Enforcement Network or his authorized delegate. Suspicious activity reports ftled under the GSA must be treated with particular care given that they contain unsubstantiated allegations of passiale criminal activity. akin to ccofidential informant tips. Unauthorized release of information collected wider the BSA may result in criminal or civil sanctions. 6L90480910001£:VS9 EFTA00151561 FinCEN Financial Crimes Enforcement Network Unit Suter Depaunmr <t the licAuty 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 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 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 S225,000.00 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 No cash or check deposit was processed; three (3) incoming funds wire transfers were processed for S580,000.00. 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 Page 9 The enclosed eformation was colected and disseminated under provisions of the Bank Secrecy Act (the SSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311. et seg.: 31 CFRChapter X. The eformation is sensitive st nature and is to be treated accordingly. The information may be used only for a purpose consistent with a crime* tax. or regulatory evestigation or proceeding. or in the conduct of etelligence or counteretelligence activities. inclueng analysis. to protect against eternational terrorism. See 31 US.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without with approval of the Director of Feancial Crates Enforcement Network or his authorized delegate Suspicious activity reports Ned under the BSA must be treated with particular care given that they contain unsubstantiated allegations of ps:c.able criminal activity. akin to cceklenbal informant tips- Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. 6L90P80910001£:VS9 EFTA00151562 FinCEN I Financial Crimes Enforcement Network United Saws Depatunan of the Ttcouty BSAR Transcript BSA: 31000150840679 and DCN: Narrative $196,673.56 payable to Palm Beach Tax.Commercial checking accoun No cash or check deposit was processed; two (2) ACH credits were processed for 50.23 and three (3) incoming funds wire transfers totaling 5298,626.14 issued by J EpsteinVirgin Island Foundation (account at The Bank of New York Mellon the reference include in the transaction was Pershing 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, LSJE LLC, 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 USA. 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 (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 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 S25,015.00 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 S300.00 payable to Government of USVI.Commercial checking account Page 10 The enclosed eformaticn was colected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasuryregulations implementing the BSA. See 31 U_S_C. 5311, et seq.: 31 CFR Chwter X. The efoimation is sensitive it nature and is to be treated accordingly The information may be used only Ice a purpose conustent with a cream* tax. or regulatory evestigation or proceeding. or in the conduct of etelligence or counteretelligence activities. including analysis, to protect against international terronsm. See 31 U_S.C. 5311. The information cannot be further released, disseminated. disclo--ed. or transmitted without prior approval of the Director of Financial CfliTICS Enforcement Network or his authorized delegate_ Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of passable criminal activity. akin to cceifklential informant tips- Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. 6L90P80910001£:VS9 EFTA00151563 ( 1.,;;;\ .FinCEN Financial Crimes Enforcement Network LIIlled States Departinait a the Ticanuty , 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 S500.00 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 53,846.00, 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 51,167.22 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 and 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 and 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; OneSumX, etc. Page 11 The enclosed reformation was collected and disseminated under provisions of the Bank Secrecy Act (Me SSA) and U.S. Department of the Treasury regaations implementing the BSA. See 31 U S C. 5311. et seq.: 31 CFR Chapter X. The reformation is sensitive ri nature and is to be treats accadingty. The information may be used only fa a purpose con ardent with acr.-nets{ tax. or regulatory rwestigation or proceeding. or in the conduct of ntelligence or counterntelligence activities. inclueng analysis, to protect against nternational terrorism. See 31 U S.C. 5311. The information cannot be further released. disseminated. disclosed. or transmitted without prior approval of the Director of Friancial Crates Enforcement Network his authorized delegate. Suspicious activity reports ftled under the GSA must be treated with particular care given that they contain unsubstantiated allegations of paastle criminal activity. akin to ccofidenhal informant tips. Unauthorized release of information collected older the GSA may recult in criminal or civil :webs:. 6L90V8091000IX:VSEI EFTA00151564