Case Document Filed Page of Tm Confidential Francis Pearn Tm Golkow Litigation Services Tm Page Tm UNITED STATES DISTRICT COURT FOR THE Tm SOUTHERN DISTRICT OF NEW YORK Tm Tm Case No JSR Tm JANE DOE Individually and on behalf of all others Tm similarly situated Plaintiffs Tm VS Tm JPMORGAN CHASE BANK N.A Tm Defendant Tm Case No JSR Tm GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS Tm Plaintiffs Tm VS Tm JPMORGAN CHASE BANK N.A Defendant Tm Tm CONFIDENTIAL Tm Tm Videotaped deposition of FRANCIS PEARN taken at the offices of Tm Boies Schiller Flexner LLP Hudson Yards New York New York before Tm Clifford Edwards Certified Shorthand Reporter and Notary Public in and for the Tm State of New York on March at a.m EDT Case Document Filed Page of Tm Confidential Francis Pearn Tm Golkow Litigation Services Tm Page Tm Tm A Yes Tm What is the relationship between a Tm background investigation and a DDR a due Tm diligence report Tm A The due diligence report is completed Tm at the time by the the banker responsible for Tm the relationship leverages information obtained Tm through searches of those systems for changes in Tm the client from a negative media PEP OFAC Tm perspective Tm Would a due diligence report during Tm this period include all of the information that Tm was a part of the background investigation Tm A The background investigation was done Tm at client on-boarding and then ongoing monitoring Tm of systems for negative media OFAC designation Tm PEPs was done as part of ongoing client Tm screening client know your client Tm What does know your client refer to Tm in your answer Tm A The the formal process that we have Tm at the bank as part of our BSA/AML program Tm When clients are new to the bank and/or Tm changes in the products and services that the Case Document Filed Page of Tm Confidential Francis Pearn Tm Golkow Litigation Services Tm Page Tm Tm clients are utilizing that may trigger updates to Tm the Know Your Customer record Tm As part of the Know Your Customer Tm process that you just described in this time Tm period did JPMorgan also look at internal Tm JPMorgan records on its customers for private Tm bank Tm MR BUTTS Objection to form Tm You may answer if you are able Tm A If it an existing client or customer Tm of the bank there would be records and they Tm would be looked at Tm BY MR ARNOLD Tm What would those internal records Tm include Tm A It would include the history of the Tm products and services used by that existing Tm client It would include any any information Tm that was identified as part of the ongoing Tm transaction monitoring there would be a history Tm record of that and that would be generally what Tm was looked at Tm Is there anything else you can think of Tm that would have been looked at in terms of as Case Document Filed Page of Tm Confidential Francis Pearn Tm Golkow Litigation Services Tm Page Tm Tm Is that a written document Tm A Yes Tm Were clients who were assigned a high Tm risk rating subject to annual Know Your Customer Tm or KYC relationship reviews Tm A Yes they were Tm What was involved in an annual Know Tm Your Customer relationship review Tm A An update to the information that Tm filed that already included in the KYC file Tm It will include searches for any change in status Tm of from an OFAC sanction perspective it Tm will it will search for if they are now Tm considered a PEP there will be the ongoing Tm negative media screening that is part of that Tm And then also a general documentation of Tm has there been any change in the customer Tm activity with the client or their the nature of Tm their products and services used at the bank Tm What was the purpose of the annual KYC Tm relationship review Tm A It it part of our procedures to Tm ensure that we are current in our understanding Tm of the client the relationships they have with Case Document Filed Page of Tm Confidential Francis Pearn Tm Golkow Litigation Services Tm Page Tm Tm A Yes Tm BY MS BOGGS Tm If a customer has a crime related to a Tm sexual offense against a minor are they a higher Tm risk for for human trafficking Tm MR BUTTS Objection to form Tm And you may answer as a Tm witness Tm A Yes Tm BY MS BOGGS Tm If a customer is a registered sex Tm offender are they a higher risk for human Tm trafficking Tm MR BUTTS Same objections Tm A Yes Tm BY MS BOGGS Tm The second bucket is Demographic Tm links to online adult advertising and services Tm And this is the category that we talked Tm about before right Tm A Yes it is Tm The third bucket is Previous AML Tm history Tm This states Previous AML history Case Document Filed Page of Tm Confidential Francis Pearn Tm Golkow Litigation Services Tm Page Tm Tm while not necessarily HT-related may be Tm associated with an investigation related to Tm suspicious activity such as interstate Tm excessive or structured cash activity Tm Do you see that Tm A Yes Tm So does this mean if a consumer has a Tm prior history of excessive or structured cash Tm activity that they would be a higher risk for Tm human trafficking Tm MR BUTTS Same objections Tm A Yes Tm BY MS BOGGS Tm Other than the documents that you and I Tm have looked at today have you seen any other Tm JPMorgan documents related to human trafficking Tm MR BUTTS Objection Form Tm You may answer Tm A No Tm BY MS BOGGS Tm Other than William Langford and Tm Mr DeLuca are there any other individuals at Tm JPMorgan that would have more knowledge about the Tm human trafficking initiatives at JPMorgan Case Document Filed Page of
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