BUILDINGART, S. DE R.L. account exceeded the Incoming and Outgoing amount for January 2016. Account 11'12645 was reviewed for the period January 2016 through February 2016. Account balance: $3,184.38 There were 2 Incoming Wires totaling $1,550,000 as follows: $1MM from DETERGENTES LTDA — household products (http://www.bloomberg com/profiles/companies/6989313Z:CBdetergentes-ltda + http://www.dersa.com.co/pagina/) at JPMC and $550K from CORSONAR SA at COUTTS AND COMPANY — related entity, Daniel Haime is a Director (https://opencorporates.com/companies/pa/199278 <https://opencorporates.com/- companies/pa/199278>). There were 14 Outgoing transactions totaling $1,062,732.26. Activity consisted of: 13 Outgoing Wires for amounts ranging from $300K to $3K. Sampling review of wires were sent as follows: $300K to JP MORGAN CHASE FFC: BREMOND FINANCIAL INC, $250K to BANK OF NEW YORK FFC: BUTTERFIELD BANK (BAHAMAS) LIMITED REF: SONIA GUTT HAIME (related party), $200K to JP MORGAN CHASE FFC: ALASTOR ENTERPRISES INC — related entity, Daniel Haime is Director & President (https://opencorporates.com/companies/pa/111591), $51.2K to FIRST MERIT BANK NA FFC: VSA PARTNERS INC - branding company (www.vsapartners.com), and $20.0K to FIRST AMERICAN BANK FFC: APPLIED WAYFINDING INFORMATION DESIGN — information design firm (www.appliedwayfinding.com <http://www.appliedwayfinding.com›). $150K Transfer to related A/C 18192776 - JESSAMINE GROUP LTD Account is under the GUTT, DANIEL RELATIONSHIP. Per KYC #01048205, BuildingArt, S.de R.L. is a Panamanian Corporation incorporated on 12/17/2012. They are involved in Architecture and construction operations in Panama and Bahamas. This checking account was established to meet settlement of invoices from engineers / architects involved in several construction operations being developed by Mr. Daniel Haime. The Haime Gutt family is a well known and reputable family in Bogota, Colombia. Additionally, Mr. Daniel Haime sold his tubing company called Tubo Caribe to Maverick Tube in 2005 for US$ 86 million. EFTA01435805 The client used their account to receive funds from a household products company and a related entity as well as to send funds to related parties/entities and pay business related expenses . Similar activity found in prior case reviews. Activity is in line with KYC and does not appear suspicious. No change in profile necessary. Tammy McFadden: Specify alerted INCOMING/OUTGOING amount/count activities for the month of January and Feb 2016 January - INCOMING amount $1,000,000.00 OUTGOING amount $740,526.26 Tammy McFadden: Missing link For internal use only For internal use only For internal use only EFTA01435806