'l g) Financial Crimes Enforcement Network L?nitcd Start-x Department ()i?lilc BSAR Transcript BSA: and DON: Filing Information Type of Report Initial Report FilinLDate 1 0/23/201 5 Received Date 1 0/23/201 5 Entry Date 1 0/26/201 5 Submission Method Electronic batch filing Subject Information Subject 1 of 1 Page 1 EN 1i111cs 11i11111111c111 1n 111111 Wpunnurnln I11.. 111 BSAR Transcript BSAr?an and Subject Information Suspicious Activity Information Amount Involved $30,000 Date or Date Range of Activity 08/04/2015 - 08/07/2015 Money laundering Transaction out of pattern for customer(s) Suspicious concerning the source of funds Structuring Multiple transactions below CTR threshold Page 2 I i Financial (:rimcs Enforcement Network In [finial Hurt-x nI r'nc lit-mutt \l BSAR Transcript BSA: and DCN: Suspicious Activity Information Other suspicious activities Transaction with no apparent economic, business, or lawful purpose Financial instrument or payment US. Currency mechanism Activity Location of Financial Institution institution OCC RSSD Number 852218 Name JPMORGAN CHASE NATIONAL ASSOCIATION EIN RSSD Number 852218 Address(ee) Street Address 1111 POLARIS PARKWAY 1111 POLARIS PKWY - Enhanced City COLUMBUS COLUMBUS - Enhanced State OH OH - Enhanced ZIP Code 43240 43240-2031 - Enhanced Country US US - Enhanced Internal Control File Number Page 3 Ij" Financial Crimes linibreement Network In \mrex Department nl BSAR Transcript and DCN: Activity Location Branch Office Location 1 of 2 Financial Institution Name JPMORGAN CHASE BANK, NATIONAL ASSOCIATION JPMORGAN CHASE BANK NATL ASSN - Enhanced RSSD Number 645018 Address Street Address 850 Third Avenue 850 3RD AVE - Enhanced City New York NEW YORK - Enhanced State NY NY - Enhanced ZIP Code 10022-6222 10022-6222 - Enhanced Country US US - Enhanced Branch Office Location 2 of 2 Financial Institution Name JPMORGAN CHASE BANK, NATIONAL ASSOCIATION JPMORGAN CHASE BANK NATL ASSN - Enhanced RSSD Number 282002 Address Street Address 725 River Rd 725 RIVER RD - Enhanced City Edgewater EDGEWATER - Enhanced State NJ NJ - Enhanced ZIP Code 07020-1171 07020-1171 - Enhanced Country US US - Enhanced Filer Information Primary Regulator OCC Filer Name JPMORGAN CHASE BANK, NATIONAL ASSOCIATION JPMORGAN CHASE BANK NATL ASSN - Enhanced EIN Page 4 . . - I i\crw0rk In lfniml \mtt-s IlahllH' \l BSAR Transcript BSA: - and DCN: Filer Information Address(es) Street Address 1111 POLARIS PARKWAY 1111 POLARIS PKWY - Enhanced City COLUMBUS COLUMBUS - Enhanced State OH OH - Enhanced ZIP Code 43240 43240-2031 - Enhanced Country US US - Enhanced of Financial Institution institution RSSD Number Internal control/file number Contact for Assistance Full Name Phone Number Law Enforcement Information No Law Enforcement Information Available Narrative JP Morgan Chase Bank NA. is filing this Suspicious Activity Report on JPMC Customer, - _sole signer on the account of The Bank of Economic Affair ("Vnesheconombank") to report cash activity totaling $30,000 that appeared to be structured to avoid CTR requirements in Commercial Checking Account The activity occurred between 8/4/2015 and 8/7/2015. Internal records identified_ as the sole signatory of account Account was opened on 4/15/2010 and is currently active. Internal records also identified that The Bank of Economic Affair ("Vnesheconombank") has been a customer since 12/7/2011. TRANSACTION DETAILS: A review of Vnesheconombank's checking account on which-is the sole signer, identi?ed that between 8/4/2015 and 08/7/2015, three (3) cash withdrawals were made all in equal distributions of $10,000. 8/4/2015; $10,000; 850 Third Avenue, New York, NY 10022 8/6/2015; $10,000; Third Avenue and 51 st Street Branch 8/7/2015; $10,000; Edgewater Branch 725 River Road, Edgewater, NJ 07020 Internet researched identified Vnesheconombank and- -as the subjects of a breach of lease suit involving a house rented by Evgeny Buryakov, a former employee and accused Russian spy. In the suit,_and the Russian Federation are accused of removing the contents of the house rented by Evgeny Buryakov after the arrest of Buryakov. _representative of Page 5 . .. . . - . i I, l'manual (,rimcs i\ctwoik In [fluted Swim nir'hc imixur'" BSAR Transcript and new: Narrative Vnesheconombank, worked alongside Evgeny Buryakov ("Buryakov"), who is noted as deputy representative of Vnesheconombank in the United States According to the Vnesheconombank homepage, State Corporation "Bank for Development and Foreign Economic Affairs (Vnesheconombank)" operates to enhance competitiveness of the Russian economy, diversify it and stimulate investment activity. Vnesheconombank is not a commercial bank, its activity is governed by special Law 82-FZ which came into force on June 4, 2007. lnternet research noted Buryakov was charged with intelligence gathering, economic espionage, and recruitment of US Nationals for the Russian Foreign Intelligence Service and respectively). A review of the above transactions noted that the withdrawals were just below the CTR requirements, which is indicative of possible structuring of funds in a manner to avoid CTR requirements. In addition,_ worked in close proximity to Buryakov, who is accused of intelligence gathering, economic espionage, and recruitment of US Nationals for the SVR. In Summary, JPMC is filing a SAR in the amount of $30,000 to report cash activity that appeared to be structured to avoid CTR requirements. Supporting documentation associated with this report (SAR includes, but may not be limited to, documents maintained or identified in case file and can be retrieved upon request. Upon the appropriate and validated request of a regulator or law enforcement agency, supporting documentation will be provided. SAR Case VNESHECONOMBANK REP OFFICE For Assistance contact JPMorgan Chase LE Fulfillment team at: Page 6