I \cmmL BSAR I BSA. Dow: 9 Information Tu): cl Repon CoMInuIng Amwriy Repori nirng Dane 02/09/2017 Received Date 02/09/2017 Entry Due 02/10/2017 Submission Memod hatch Subject Information Hale Subject I 0T3 FENERO EQUITY INVESTMENTS LP Subject Subjeu Type Both Purchaser arm Payee Individu-VOrg-nIz-iion ngamzaimn usi (m Enmy) Name FENERO EQUITV INVESTMENTS LP FENERO EQUITV INVESTMENTS - Ennancea TIN Yes Farm(si al IdemiIie-iion Yes Address(es) streei Address any ZIP Code Caumry VI VG - Ennancea al Euslness INVESTMENT FUND Carmimmive Suiemeni io Filer Ne lo Hepanin -- Relationship aI Sumac! Ne HelaIIonshIp Yes Page 1 VSE 7 I LilCiimmliil'ur m'ni\tn\riiL WW BSAR Transc I DON- Subject Information Allecteo Accouiit(s) "mm" on Account Number Financial Institution TIN Account 2 ol 7 Account Number Financial Institution TIN Account 3 ol 7 Account Number Financial Institution TIN Account 4 ol 7 Account Number Financial Institution TIN Account 5 ol 7 Account Number Financial Institution TIN Account 5 ol 7 Account Number Financial Institution TIN Account 7 ol 7 Account Number Financial Institution TIN Sub (:12 ms FENERO SWITZERLAND LP Hale Suhieci Suoiect Type Purchasel/Sender liioivmual/Oiganiution Oigamzation Last (oi Enmy) Nanie FENEFIO FINANCIAL LP FENEFIO FNCL - Enhanced TIN unknown Yes Foim(s)oiloeiitilication Iuentiricatioii unknown Yes Aooress(es) Street Address city ZIP Code unknown Country Vl VG - Ennanceo Page 2 --1V88 I I'IImmnl l'numul mm $1an BSAR Transcn BSA --"and new Suspi ous Activity Information Dlie or Date Range ai Anivily 07/07/2016 - 12/25/2016 Maney laundering Suspicious EFT/wlve (vansiers Suspicious use oi mulupie accounts Suspicious ihe source oi Iunds Fraud Pyramrd scheme orher suspicious lemme; Transacncn nc apparenl busuness, cr lawM purpose financia inerrurnenmp enl Fundsuansier mach-mam Activity Location Mc Bunch Involved Ves Tu): airinan .I Inniiunen Denotilory in Primlry Fedevai Resewe Number Legal Nlme THE BANK OF NEW VORK MELLON EIN Number Addremee) Street Addren 225 LIBERTV STREET 225 LlaEnTv ST - Enhanced 0in NEW VORK NEW VORK - Enhanced Sine NV NY - Enhanced zn: ecde 10286 10281-1048 - Enhanced Caumry us us - Enhanced Internal Control File Number-- Filer Information Primary Regularer Federal Reserve filer Name THE BANK OF NEW YORK MELLON THE BANK OF NEW YORK MELLON - Enhanced em -- Page 4 --1VSS .mLinl mo \L'rwmk I I 1mm BSAR Transcn I BSA DON: Filer Information Addrenm) Sum Address 225 LIBERTY STREET 225 LIBERTY ST - Enhanced City NEW YORK NEW YORK - Enhanced Sure NY NY - Enhanced Code 102019 10281-1048 - Enhanced Country US US - Enhanced Type 111 Financial Depository Immunon Number Inlemal control/file number Comm 1m nuisance Full Nlme LEGAL DEFT Phone Number Type Work Number Law Enforcement Informakion No Law EnIcrcemenI InIormahcn AvaIIanIe Narrative THE BANK OF NEW YORK MELLON INTERNAL REFERENCE- THE BANK OF NEW YORK MELLON (BNYM) IS FILING THIS SAR TO REPORT 16 SUSPICIOUS WIRES, TOTALING 5137,8051'485 2o (REFLECTING THE DEBIT AMOUNT CONVERTED TO USD), INVOLVING IMS INTERNATIONAL MARKETING SERVICES A SHELL ENTITY REPORTEDLY RELATED TO ONECOIN WHICH IS MARKETED AS A VIRTUAL BUT HAS ALSO BEEN ACCUSED OF OPERATING A PONZI SCHEME THE WIRES ALSO INVOLVE FENERO EOUITY INVESTMENTS LP AND FENERO FINANCIAL SWITZERLAND BVI INVESTMENT FUNDS THAT RECEIVED WIRES FROM SHELL ENTITIES ASSOCIATED WITH ONECOIN THIS SAR SUPPLEMENTS A PRIOR FILED 12/22/2010 WHICH REPORTED SUSPICIOUS WIRE ACTIVITY INVOLVING INTERNATIONAL MARKETING SERVICES PTE LTD ANOTHER SHELL ENTITY ASSOCIATED WITH ONECOIN THE PREVIOUSLY REPORTED ACTIVITY TOOK PLACE FROM 05/23/2016 TO 11/07/2016 AND TOTALED $222,000,450 00 (BNYM INTERNAL REFERENCE 0622598) THE WIRES REPORTED IN THIS SAR WERE CONDUCTED THROUGH BNYM CORRESPONDENT ACCOUNTS BNYM MAINTAINS CORRESPONDENT BANKING RELATIONSHIPS WITH FOREIGN FINANCIAL INSTITUTIONS THUS ENABLING THOSE INSTITUTIONS TO CONDUCT TRANSACTIONS IN DOLLARS ON BEHALF OF THEMSELVES AND THEIR --=vss Financial CIimu Network BSAR TranSCrI 1 BSA --'3-4nd Dow: Narratlve CUSTOMERS BNVM MAINTAINS A DIRECT RELATIONSHIP SOLELV WITH THE FOREIGN FINANCIAL INSTITUTION AND DOES NOT HAVE ANV RELATIONSHIP WITH THAT INSTITUTIONS CUSTOMERS THE WIRES REPORTED IN THIS SAR ARE SUSPICIOUS BECAUSE (I) INTERNET RESEARCH INDICATES THAT ONECOIN, A THAT OPERATES A PONZI SCHEME, HAS OPENED BANK ACCOUNTS USING SHELL COMPANIES INCLUDING IMS INTERNATIONAL MARKETING SERVICES GMBH AND INTERNATIONAL MARKETING SERVICES PTE (2) THESE SHELL COMPANIES SENT WIRES TO FENERO EOUITV INVESTMENTS LP AND FENERO FINANCIAL SWITZERLAND LP, WHICH ARE REPORTEDLV INVESTMENT FUNDS REGISTERED IN THE HIGH-RISK JURISDICTION OF (3) THE INVESTMENT FUNDS THEN SENT WIRES, PRIMARILV TO OTHER RELATED ENTITIES, FURTHER LAVERING THE (A) ONE WIRE SENT BV FENERO EOUITV INVESTMENTS LP BENEFIT-TED A HONG KONG SHELL ENTITV AND REFERENCED WHICH IS ALSO ASSOCIATED WITH ONECOIN, AND (5) THE WIRES WERE SENT IN LARGE AMOUNTS AND SOME WERE REPETITIVE, WITH MULTIPLE WIRES SENT ON THE SAME DAV BACKGROUND INTERNET RESEARCH INDICATES THAT ONECOIN, FOUNDED BV RUJA IGNATOVA, OPERATES AS A SCAM, AND IT HAS BEEN SUBJECT TO INVESTIGATIONS AND INVESTOR WARNINGS IN NUMEROUS JURISDICTIONS INCLUDING THE UK, BELGIUM, SWEDEN, AUSTRIA, LATVIA, AND SINGAPORE ARBEITERKAMMER AT, FKTK HTTP MAS GOV COM: FCA ORG UK, FSMA BE, BITCOIN WIKIPEDIA INTERNET RESEARCH INDICATES THAT ONECOIN ROUTINELV OPENED BANK ACCOUNTS USING SHELL COMPANV NAMES, INCLUDING INTERNATIONAL MARKETING SERVICES PTE LTD AND IMS INTERNATIONAL MARKETING SERVICES GMBH COM, BLOGSPOT HTML, BLOGSPOT AS REPORTED IN THE PRIOR SAR, AFTER TWO WIRES SENT FOR THE BENEFIT OF INTERNATIONAL MARKETING SERVICES PTE LTD WERE RETURNED BV BENEFICIARV BANK UNITED OVERSEAS BANK LIMITED (SINGAPORE) CITING ITS BNVM CONDUCTED A SCAN FOR WIRE ACTIVITV INVOLVING THE ENTITV THE SCAN IDENTIFIED WIRES SENT BV INTERNATIONAL MARKETING SERVICES PTE LTD FOR THE BENEFIT OF FENERO FINANCIAL SWITZERLAND LP AND FENERAL EOUITV INVESTMENTS LP, BOTH BANKING AT-- (GEORGETOWN, CAVMAN ISLANDS) AS A RESULT OF THE PRIOR ACTIVITV, BNVM CONDUCTED A SCAN FOR WIRE ACTIVITV INVOLVING FENERO EOUITV INVESTMENTS LP, FENERO FINANCIAL SWITZERLAND LP, AND INTERNATIONAL MARKETING SERVICES FOR THE PERIOD FROM 7/6/2015 TO 1/5/2017 AND IDENTIFIED Is SUSPICIOUS WIRES, TOTALING $137,6u9,489 20 (REFLECTING THE DEBIT AMOUNT CONVERTED TO USD), THAT -=vsa mm \L'Twork 1 mm, mm IWI BSAR TranScn I BSA DON: Narrative WERE SENT FROM 7/7/2016TO12/2Iz/2u1s ACCORDING TO INFORMATION RECEIVED FROM-- - FENERO EOUITV INVESTMENTS AND FENERO FINANCIAL SWITZERLAND IS THE FIRST OF A SERIES OF $100,000,000 OPEN-ENDED INVESTMENT FUNDS LOCATED IN THE BRITISH VIRGIN ISLANDS FOCUSING ON INVESTMENTS IN THE FINANCIAL SERVICES INDUSTRV IN EUROPE THE PRIMARV OBJECTIVE OF THE CLIENT IS TO INVEST INTO CONTROLLING POSITIONS OF DISTRESSED COMPANIES IN THE FINANCIAL SERVICES INDUSTRV THE CLIENT IS CURRENTLV ADMINISTERED AND MANAGED BV MSS INTERNATIONAL CONSULTANTS LLC, WHICH IS ULTIMATELV OWNED BV AMERICAN ATTORNEV MARK SCOTT MARK SCOTT HAS CONFIRMED TO--THAT THE CLIENT IS IN THE NEGOTIATION STAGES OF SECURING A NEW ADMINISTRATOR NAMELV TRINITV FUND ADMINISTRATION LTD THE CLIENT HAS BEEN A CUSTOMER OF- -SINCE Ina/11912016, AND MAINTAINS A REGISTERED OFFICE ADDRESS AT-- --BRITISH VIRGIN ISLANDS FENERO EOUITV INVESTMENTS AND FENERO FINANCIAL SWITZERLAND ARE ON THE BVI FINANCIAL SERVICES COMMISSION LIST OF APPROVED FUNDS (HTTP BVIFSC ASPX) KVC INFORMATION INDICATES THAT FENERO EOUITV INVESTMENTS LP WAS FORMED IN BVI ON 03/01/2016 MSS INTERNATIONAL CONSULTANTS (BVII LTD IS LISTED AS THE GENERAL PARTNER AND CONSULT EOOD IS LISTED AS THE LIMITED PARTNER LEXISNEXIS RESEARCH INDICATES THAT CONSULT EOOD IS A PROVIDER OF MANAGEMENT CONSULTING SERVICES, AND--IS LISTED AS MANAGER ACCORDING TO ITS WEBSITE BBN CONSULT IS INVOLVED IN REAL ESTATE CONSULTANT, AND BROKERAGE SERVICES ITS MAIN OFFICE IS IN SOFIA, BULGARIA BNCONSULT PHP) AS REPORTED IN THE PRIOR SARI THE WIRES SENT FROM INTERNATIONAL MARKETING SERVICES PTE LTD FOR THE ULTIMATE BENEFIT OF FENERO FINANCIAL SWITZERLAND REFERENCED INTO CAPITAL PAYMENT ON BEHALF OF BAND CONSULT ALTHOUGH BNVM COULD NOT ESTABLISH A LINK BETWEEN CONSULT AND ONECOIN FOUNDER RUJA IGNATOVA, INTERNET RESEARCH INDICATES THAT RU.IA IGNATOVA HAS SPENT OVER $20 MILLION ON BULGARIAN PROPERTY (HTTP H1'rP1/Www CAPITAL KVC INFORMATION INDICATES THAT FENERO FINANCIAL SWITZERLAND LP WAS INCORPORATED ON us/us/zoIs, MSS INTERNATIONAL CONSULTANTS (BVI) LTD IS THE GENERAL PARTNER AND ELIAN NOMINEES (BVI) LIMITED IS THE INITIAL LIMITED PARTNER KVC INFORMATION INDICATES THAT MSS INTERNATIONAL CONSULTANTS (BVI) LTD WAS REGISTERED IN BVI ON 02/25/2016, AND ITS DIRECTORS ARE AMERICANS DAVID nusszKE--usmsm- --=vss I FHLIHLIJI mm \L'Twmk 001an II, I, I BSAR Transcn I BSA Dew: Narrative MSS INTERNATIONAL CONSULTANTS LLC -- --IS THE SOLE MEMBER AND SHAREHOLDER OF MSS INTERNATIONAL CONSULTANTS (BVI) LTD INTERNET RESEARCH INDICATES THAT MARK IS THE REGISTERED AGENT FOR FLORIDA ENTITV MSS INTERNATIONAL CONSULTANTS LLC ORG) MSS INTERNATIONAL CONSULTANTS (BVI) LTD IS ON THE BVI FINANCIAL SERVICES COMMISSION LIST OF APPROVED MANAGERS (HTTP BVIFSC ACCORDING TO HIS LINKEDIN PAGE, MARK SCOTT IS FOUNDER AND CEO OF MSS INTERNATIONAL CONSULTANTS (BVI) LTD WHICH SEVERAL HUNDRED MILLION EUROS IN A SERIES OF REGISTERED PRIVATE EOUITV FUNDS AND FOCUSES ITS INVESTMENTS ON OPPORTUNITIES IN FINTECH, FINANCIAL SERVICES, TELECOM AND HOTEL RELATED REAL ESTATE DEVELOPMENT IN ING LINKEDIN COMIINIMAFIK-S-SCOTT-5738751B) ACCORDING TO INTERNET RESEARCH, MARK SCOTT WAS ADMIT-IED To THE FLORIDA BAR ON 7/27/1930 AND IS IN GOOD STANDING (BAH NUMBER 142549) FLORIDABAR ORG) HOWEVER, AND INTERNET RESEARCH INDICATE THAT HAS BEEN ASSOCIATED WITH NUMEROUS COMPANIES, INCLUDING TWO REGISTERED IN OCTOBER 2014 THAT ARE CURRENTLV INACTIVE, WHICH APPEAR TO HAVE BEEN INVOLVED IN BINARV OPTIONS FOREIGN EXCHANGE TRADING BINARVHOLDINGS, LLC AND SPOTFN COM, LLC WIRE DETAILS ADDITIONAL DETAILS FOR ALL WIRES REPORTED IN THIS SAR CAN BE LOCATED IN THE ATTACHED CSV FILE (THE CSV FILE CONTAINS INFORMATION FOR I7TRANSACTIONS ONE TRANSACTION COULD NOT BE COMPLETED AS ORIGINALLV INSTRUCTED BUT WAS COMPLETED VIA AN ADJUSTMENT, AND DETAILS FOR BOTH TRANSACTIONS ARE INCLUDED IN THE ATTACHMENT) I WIRES SENT Bv IMS INTERNATIONAL MARKETING SERVICES GMBH FROM 7/7/2010 To 0/1/2010, IMS INTERNATIONAL MARKETING SERVICES GMBH -- GREVEN), ACCOUNT WITH DEUTSCHE BANK AG (FRANKFURT, GERMANV), SENT 5 WIRES TOTALING $27 222 500 00 FOR THE ULTIMATE BENEFIT OF FENERO EOUITV INVESTMENTS -- --BRITISH VIRGIN ISLANDS) AT -- CAVMAN ISLANDS, BNVM CORRESPONDENT ACCOUNT- ALL WIRES SENT IN THE AMOUNT OF 5,000,000 00 EUR, AND THE DETAILS OF PAVMENT FOR ALL WIRES READ PAVMENT FOR AS REPORTED IN THE PRIOR SAR, WIRES SENT FROM INTERNATIONAL MARKETING SERVICES PTE LTD FOR THE ULTIMATE BENEFIT OF FENERO EOUITV INVESTMENTS LP WERE SENT IN THE SAME AMOUNT AND LISTED THE SAME DETAILS OF PAVMENT AS THE WIRES SENT BV IMS INTERNATIONAL MARKETING SERVICES GMBH II WIRE REFERENCING ON 07/13/0016, FENERO EOUITV INVESTMENTS LP-- _Accou~m--cAvVA~ ISLANDS, BNVM CORRESPONDENT ACCOUNT--, SENT ONE WIRE IN THE AMOUNT OF $30,000,000 00 Page a --=vss 1 1 I'mmul math I I I BSAR Transcri I Dc~= Narrative FOR THE ULTIMATE BENEFIT OF BARTA HOLDINGS LTD-- (HONG KONG) LIMITED (HONG KONG, BNVM CORRESPONDENT ACCOUNT THE DETAILS OF PAVMENT READ LOAN FOR INTERNET RESEARCH INDICATES THAT 100% OF THE SHARES OF BARTA HOLDINGS LTD ARE HELD BV HUI CHI MING, WHO IS ALSO A DIRECTOR OF SINO UNION ENERGV INVESTMENT GROUP LTD (HTTP HKEXNEWS HKI ACCORDING To ITS WEBSITE INVESTMENT TRUST IS RUN BV ONECOIN ITS WEBSITE ALSO INDICATES THAT ENTERED INTO AN AGREEMENT WITH HOIFU ENERGV TO BUV A PETROLEUM FIELD IN MADAGASCAR HUI CHI MING, THROUGH VARIOUS COMPANIES IS THE CONTROLLING SHAREHOLDER OF HOIFU ENERGV COM, HTTP HOIFUENERGV HTML) WIRES SENT BV INVESTMENT FUNDS TO RELATED PARTIES ON 5/19/2010 FENERO EOUITV INVESTMENTS LP -- ISLANDS, BNVM CORRESPONDENT ACCOUNT - SENT ONE WIRE IN THE AMOUNT OF 51,045,344 00 THROUGH BNVM FRANKFURT FOR THE ULTIMATE BENEFIT OF FENERO EOUITV 0mm INTERNET RESEARCH INDICATES THAT FENERO EOUITV INVESTMENTS (IRELAND) LIMITED REGISTERED ON 04/05/2010 AND ITS DIRECTOR IS MARK SCOTT (HTTP SOLOCHECK ON 09/06/2015, FENERO EQUITV INVESTMENTS LP CAVMAN ISLANDS, BNVM CORRESPONDENT ACCOUNT -, SENT ONE WIRE IN THE AMOUNT OF $278 850 00 FOR THE ULTIMATE BENEFIT OF MARK SCOTT, -- BRITISH VIRGIN ISLANDS VG1110) AT FLORIDAI THE DETAILS OF PAVMENT READ FEES AND EXPENSES FOR LOAN FACILITVII AND FURTHER DISTRIBUTIONS FROM 09/22/2010 TO 10/17/2015, FENERO EQUITV INVESTMENTS LP _1 ACCOUNT WITH -- CAVMAN ISLANDS, BNVM CORRESPONDENT SENT 4WIRES TOTALING 255401720000 FOR THE ULTIMATE BENEFIT OF FEI IRELAND AT--IRELANDI THE DETAILS OF PAVMENT REFERENCED OF FENERO SECURITIES TRADING LIMITED OF FORMATION AND INFRASTRUCTURE OF SIF FUND AND OF MSSI MANAGED ONE WIRE WAS SENT THROUGH-- (LONDON, ENGLAND, BNVM CORRESPONDENT ACCOUNT - ON 09/29/2010, FENERO FINANCIAL SWITZERLAND LP (--TORTOLAI, ACCOUNT WITH -- LTD (GEORGETOWN, CAVMAN ISLANDS, BNVM CORRESPONDENT ACCOUNT--AND- SENT Two WIRES TOTALING $14,959,000 00 FOR THE ULTIMATE BENEFIT OF FENERO EQUITV INVESTMENTS Page 9 --=vsa [f'ti'ss'r-n' BSAR Transcri I Dc~= Narrative IIRELAND) (DUBLIN IRELANDI AT-- THE DETAILS OF READ FUNDING OF ACCOUNTS OF FENERO SECURITIES TRADING LTD ONGOING EXPENSES OF FENERO GROUP IN UK (EXCLUDING LUX SIF ONE SENT THROUGH --ILONDON, ENGLAND, CORRESPONDENT ACCOUNT FROM 11/4/2016 TO 12/28/2015 FENERO LTD ISLANDS, BNVM CORRESPONDENT ACCOUNT-I SENT 2 WIRES TOTALING 535,735 20 FOR THE IILTIMATE BENEFIT OF CAYMAN-104627DI-USD -- --anmsn vmew Isms - AT -- BANK (GEORGETOWN CAVMAN ISLANDS) THE DETAILS OF PAYMENT READ OPERATING FC THE FIRST WIRE COULD NOT BE APPLIED AS INITIALLY BUT IT WAS COMPLETED SUCCESSFULLV ON 11/07/2016 ACCORDING TO HIS LINKEDIN PAGE MARK SCOTT IS THE CEO OF MSSI LINKEDIN COMIINIMARK-S-SCOTT-5738751B) Page To --=vsa Dale of Re on Subject Your Case No Case No FEEDBACK FORM Thank youfm' as an m/m-mrman moms to snppan anr rm-mrgunan We wan! huu 2 can St'l'rt' better Please tulle mmule to [all 1 In "hat way did Ihe rnfornrauon your rnvesugauam (Please circle all Ihal apply Provlded ne\\ .nfarmauan Yes No Helpful ln movlng an Yes No Pending Expanded investigation Yes No Pending new leads/subjects Yes No Verified ensung .nfarmauan Yes No 2 Iffinanclal (Bank Secrecy Act) .nfarmauan "as proyrded, was useful for your rnvesngauam Yes No 3 Was rlre mfarmauan urne Io be useful 10 your rnvesugauam Yes No Ifnol was [here a due date |nd|caled for Ihe |nf0rmauon" Yes No 4 nemork you to anarlrer agency rlrar had prevlously made a requesl" Yes No lfyau and rlrar olher agent}. snared rnforrnauon, "as useful" Yes No 5 Overall were you sausned ""11 the service provided Yes No Comments'7 Signature: Date: Please print name: Please fax hard copy surveys to the Customer Feedback or mail to: Financial Crimes Enforcement Network The financial Ill-lib": (unliinrd in Ihix report cannot 1t. disseminated Australian Reportt Analytit Centre and the Auttralinn Tmtittn 0111:. (Am) and 1t hat he card as eritlentittry material, pmentul in (nurL In in any other prior mitten or the Financial Crimes [nt'uroerrtent INVESTIGATIVE MEMORANDUM Requester Australtan Transacttort Reports and Request Received Aprt14,201o Artalt Centre (AUSTRACI Attn Case Number Australta Requester Case Number Sub ect SYNOPSIS searched financtal systems for tnformatton on and approxtmately 1,200 subjecIs, the subjects ofPanama Papers lnvesttgattort, pursuant to a request AUSTRAC on Aprt1 4, 2016 onhe 1,200 approxtmate and requested, research returned posmve results for 57 subjects Research tn the financtal databases returned 1 l4 Reports, 1,529 Transactton Reports (CTRs) for $26,672,579, 12 Reports of lnternattonal Transportatton ofCurrency or Monetary Instrument (CMle) $215,779, 61 Reports ofForelgn Bank and Ptnanctal Accounts (FEARS) and mo Deslgnallons ofExempl Person (DOEPs) Please See the secllon reaon for funher detalls AUSTRAC, Chatswood, Australla Date A [Is] oft/re databaxex researched by can be found at the end oft/"t repurl NARRATIVE Analyst ancl Please note that the dates contatrted tn report are tn (monthl (day) (year) format For example, August 1, 2011 ma}. he as 08/01/2011 or 08/1/11 Analyst Note Research was to exact name matches only due to the 1tmtted Idemlfiers prm'lded Some names returned posmve results but only those \Mlh a locattort or to the address prm'lded were tnoluded Analyst Note: The word "structurtng" as used tn repon refers to dellbemtel}. breaktng up a large transactton tnto amounts small enough to not mgger a Currency Transaettort Report (for cash transacttons over $10,000) or recordkeeplng and tdenttfioatton requtremertts (for \Mres or money servtces bustness transacttons of $3,000 or more] The tntent of structunng ts to evade the repomng or recordkeeplng requtrements Provided Inform: on Linked Com an Address: Australia Mancini Database Result: Arm-n Re 01 SAR Number is Idennfied as a subjeu ofthe follmung Suspmous Acuvny Repon mvolvmg money laundenng and corrupnon Auim, Dalnm SAR run Ind Activity Locminn Acuim, Daln(s) SAR Filer and Activity Locminn Decemher 03 $541,644 2015 2 Februur} 2 . 201a Auslrulm One Nemork Semcee L1d One EUX Huron Lauderdale. Florrdd) One Corn THE SAR PROVIDED THE FURHATIU AR 15 herng rrled |u repon 1he xuue oru um 1hu1 Wm upened ruran enuu h) 1he name unned h) -- The pumme uflhe' ror1he purch se ul'urgumu produc huneuer hemeen 12/03/20 nd 02/24/2016 1he c1ren1conduc1ed 13 uggregure 4n 1o mum )0 AUD) The pun-Awe or mew |mn>uL|mm rur un rmedmem In Vlnuul current) cumpum. by 1he nurne umneCo .\\hlch ne xumedcuuld be' cam due |u euem lmsem'ch The funds ror pmmenu nere mm 1o an dua1 Tending 7 ("Beneficmn 111. an enuu under 1he name EUX LLC hu, ed me 115 ("Benet-mar} 211 und an enm) under 1he nume NETWORK SERVICES LTD hmed Bulgurm ("Benet-mar} The repuned purenuul anmluus 2mm") \ma de1ec1ed on 02/24/2o1h Thu reion herng ucuul) processed rorchen1 uc swmer ur-- haeedrnAudrahu . epcn) The chem hm held un uccounn nuh - rnce 11/25/2012 The chem a manurac1urer und dmnbuwr <e11f>k1n [muluuh On 02/24/2011>> - uccounn repreuemmlve rnrorrned -1hu11he chen1hud 1hu1 1he 13 punmenu rnenuoned Ahm'e nere relured 1o un 1me>|mem mu Hnum curren 7 compum h) 1he name Company") 1n uddruon 1he Chem confirmed 1he wurce or 1he funds uulued 1o rund Ihese puymenh came rrom mud puruee hu1 1he nere mu Due perrormed on 1he compum 1hu1 1he compam 1s unned und ruunded Dr Rum Ignuww und .1 could he expmed "G1oha1 Pom Scheme" Apparenrh 1he compam 1s ufienng h1gh percenuge on re|urm The} are 1hu1 12 mon1h chem: can huue re1urn on rherr rmedmem {Sunrtn 111hup//curn1e1egruph cum/nevu/untu Imp I/Iruqumr-umpumes mm/onemInrvaewl) Due to me derogatory Informanon round, AFEX >u>pec| about me legmmaty onhe rmemem com I Below are The hank LIeIarls wine}: are 13 payment) were sem lo Beneficmry USD Accnum Accnum number fi Bunk Name BANGKOK BANK PUBLIC COMPANY LIMITED Bunk Country Thmland IPMURGAN CHASE BANK A Bunk Coumry Unued smes AUD and EUR Accnum Accnum number - Bunk Name KASIKORNBANK PUBLIC COMPANY LIMITED Swlfi Bank Bank Cnumry Benween Iz/Is/znls and 02/24/2015, Ihe Chem senI 7 payment) "3 Benenmry I for Lhe Ioml amoum 01342134 on (Equnalem 58,417 40 AUD) #2 Accoum number Bank Name TD BANK NA ABA --Accoun| Bunk Coumry Umled Smes Benween woman and max/2015, Ihe Chem senI 3 payment) "3 Benenmry 2 for Lhe Ioml amoum 0134997 00 (Equmlem m6,839 2| AUD) #3 Accoum number -- Bank Name CAPITAL BANK JOINT STUCK COMPANY SwIfl Bunk Bank Cnumry Georgm On Iz/03/20 Ii Lhe Chem sent 3 paymems lo Beneficmry 3 for Ihe Imal amount mu 13 on (Equndlem to 4553 35 AUD) Based on Ihe above Lhe Chem accoum was closed and "us SAR Is bemg med FEEDBACK FORM Please complete the attached feedback form and return the form via mail or fax to FinCEN as soon as possible. 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Financial (Bank Secrecy Act) Database: NOTE: Due to privacy laws in the United States, FinCEN is unable to obtain certain banking information, such as the names of account holders, account statements or balances, or any credit card information. Should you require such information, you may consider making such a request under the provisions of a Mutual Legal Assistance Treaty (MLAT) or via letters rogatory. Transaction information from FinCEN is limited to that reported under the Bank Secrecy Act requirements: • Financial Database: Bank Secrecy Act information from at least the past 10 years. Includes: • Currency Transaction Reports (CTRs) • Designation of Exempt Person forms • Reports of International Transportation of Currency or Monetary Instruments (CMIRs) • Currency Transaction Reports by Casinos (CTR-Cs) • Form 8300’s, Reports of Cash Payments Over $10,000 Received in a Trade or Business • Reports of Foreign Bank and Financial Accounts (FBARs) • MSB Registration • Suspicious Activity Reports (SARs) 7