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UNITED STATES DISTRICT COURT FOR THE 
SOUTHERN DISTRICT OF NEW YORK 
GOVERNMENT OF THE UNITED 
) 
STATES VIRGIN ISLANDS 
) 
) 
Plaintiff, 
) 
) 
V. 
) 
) 
JPMORGAN CHASE BANK, N.A. 
) 
) 
Defendant/Third-Party Plaintiff. 
) 
JPMORGAN CHASE BANK, N.A. 
) 
) 
Third-Party Plaintiff, 
) 
) 
V. 
) 
) 
JAMES EDWARD STALEY 
) 
) 
Third-Party Defendant. 
) 
 
) 
Case Number: 1:22-cv-10904-JSR 
ACTION FOR DAMAGES 
JURY TRIAL DEMANDED 
SECOND AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL 
Plaintiff Government of the United States Virgin Islands ("Government") files this 
Complaint against JPMorgan Chase Bank, N.A. ("JP Morgan") for violations of Trafficking 
Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and 
Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and 
Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges as 
follows: 
PARTIES 
I. 
The Attorney General of the United States Virgin Islands (hereinafter "Virgin 
Islands") brings this parens patriae action on behalf of the Plaintiff, Government of the Virgin 
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Islands, pursuant to 15 U.S.C. § 1595(d) and 3 V.I.C. § 114 and her statutory authority to enforce 
the laws of the Virgin Islands and protect public safety. 
2. 
The Attorney General, pursuant to her authority to represent the Government of the 
United States Virgin Islands, also acts on behalf of, and with the lawfully delegated authority of, 
the Virgin Islands Department of Licensing and Consumer Affairs under 12 V.I.C. § 327 in regard 
to Count Four of the Government's Complaint alleging violations of the Virgin Islands Consumer 
Fraud and Deceptive Business Practices Act. 
3. 
This action stems from an enforcement action the Government filed against the 
Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey 
Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations 
Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke et at, Case No. ST-20-
CV-14 (Super. Ct. V.I. Jan. 15, 2020). The Attorney General brings this action, after presenting 
her findings to JP Morgan in September 2022, in her ongoing effort to protect public safety and to 
hold accountable those who facilitated or participated in, directly or indirectly, the trafficking 
enterprise Epstein helmed. The investigation revealed that JP Morgan knowingly, negligently, and 
unlawfully provided and pulled the levers through which recruiters and victims were paid and was 
indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial 
institutions can connect—or choke—human trafficking networks, and enforcement actions filed 
and injunctive relief obtained by attorneys general are essential to ensure that enterprises like 
Epstein's cannot flourish in the future. 
4. 
Defendant JPMorgan Chase Bank, N.A. is an American multinational investment 
bank and financial services company headquartered in New York City and incorporated in 
Delaware. 
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5. 
At all relevant times, JP Morgan engaged in business in the Virgin Islands, 
including, but not limited to, the acts and practices described herein. 
6. 
As described below, based on documents reviewed and interviews conducted by 
the Government, JP Morgan knowingly facilitated, sustained, and concealed the human trafficking 
network operated by Jeffrey Epstein from his home and base in the Virgin Islands, and financially 
benefitted from this participation, directly or indirectly, by failing to comply with federal banking 
regulations, 
JP Morgan facilitated 
and concealed wire and cash transactions that raised suspicion of—and were in fact part of—a 
criminal enterprise whose currency was the sexual servitude of dozens of women and girls in and 
beyond the Virgin Islands. Human trafficking was the principal business of the accounts Epstein 
maintained at JP Morgan. 
7. 
Upon information and belief, JP Morgan turned a blind eye to evidence of human 
trafficking over more than a decade because of Epstein's own financial footprint, and because of 
the deals and clients that Epstein brought and promised to bring to the bank. These decisions were 
advocated and approved at the senior levels of JP Morgan, including by the former chief executive 
of its asset management division and investment bank, whose inappropriate relationship with 
Epstein should have been evident to the bank. Indeed, it was only after Epstein's death that JP 
Morgan belatedly complied with federal banking regulations regarding Epstein's accounts. 
JURISDICTION, VENUE, AND RELATED CASE 
8. 
This action is brought pursuant to and based on federal and Virgin Islands statutes, 
including the federal Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595 ("TVPA"), 
and the federal Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336 and its implementing regulations 
("BSA"). 
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9. 
This Court has federal question subject-matter jurisdiction pursuant to 28 U.S.C. 
§ 1331 because the Government's TVPA and BSA-based causes of action arise under federal law. 
10. 
This Court has supplemental jurisdiction over the Government's Virgin Islands law 
claims pursuant to 28 U.S.C. § 1367(a) because these claims are so related to those arising under 
or based on federal law as to form part of the same case or controversy under Article III of the 
United States Constitution. 
II. 
This Court is an "appropriate district court of the United States" in which for the 
Government to obtain appropriate relief under 18 U.S.C. § 1595(d) and venue is proper under 28 
U.S.C. § 1391(6)(2) because Defendant maintains its principal place of business within this 
judicial district, so that this Court may exercise general personal jurisdiction over Defendant, and 
because many of the alleged acts and omissions of Defendant giving rise to the Government's 
claims took place within this judicial district, so that this Court may exercise specific personal 
jurisdiction over Defendant. 
12. 
Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is 
related to Doe I v. JP Morgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because 
both actions arise from a common nucleus of operative fact involving Defendant JP Morgan's 
alleged participation, directly or indirectly, in Epstein's sex-trafficking venture by facilitating 
payments to women and girls, channeling funds to Epstein to fund the operation, and concealing 
Epstein's criminal conduct by failing to comply with federal banking regulations. 
BACKGROUND 
I. 
JP Morgan's Federal and State Legal Requirements 
13. 
JP Morgan is subject to federal laws, including the BSA and the Uniting and 
Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct 
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Terrorism Act of 2001, Pub. L. No. 107-56, 115 Stat. 272 ("USA PATRIOT Act"), which amended 
certain BSA regulations. 
14. 
Under both the BSA and USA PATRIOT Act, JP Morgan is required to implement 
adequate, risk-based anti-money laundering ("AML") policies and systems to detect and prevent 
money laundering or other use of the institution's services to facilitate criminal activities. This 
includes, but is not limited to, maintaining a due diligence program, filing suspicious activity 
reports ("SARs") when the financial institutions detect suspicious behavior and currency 
transaction reports ("CTRs") for currency transactions or series of currency transactions that 
exceed $10,000 in a 24-hour period, preventing structuring or assistance with structuring of 
transactions undertaken for the purpose of evading federal reporting requirements, and maintaining 
systems to prevent money laundering. 
15. 
The FDIC and the other federal banking regulators, including the Federal Reserve 
Board and Office of the Comptroller of the Currency, formed an interagency organization known 
as Federal Financial Institutions Examination Council ("FFIEC"). 
16. 
To provide further guidance to banks on what BSA compliance requires, FFIEC 
published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). 
The BSA Manual explains that an effective SAR program is essential: 
Suspicious activity reporting forms the cornerstone of the BSA reporting system. It 
is critical to the United States' ability to utilize financial information to combat 
terrorism, terrorist financing, money laundering and other financial crimes. 
Examiners and banks should recognize that the quality of SAR content is critical to 
the adequacy and effectiveness of the suspicious activity reporting system.' 
17. 
Pursuant to the BSA Manual, "[p]roper monitoring and reporting processes are 
FFIEC Bank Secrecy AcUAnti-Money Laundering Examination Manual. Suspicious Activity 
Reporting at 1 (2014) 
https://bsaaml.ffiec.gov/docs/manual/06_AssessingComplianceWithBSARegulatoryRequirement 
s/04.pdf. 
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essential to ensuring that the bank has an adequate and effective BSA compliance program. 
Appropriate policies, procedures, and processes should be in place to monitor and identify unusual 
activity."2 When a bank detects suspicious activity, it is required to report that information within 
30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network 
("FinCEN"). The reporting requirement ensures that the government is able to monitor and act 
when alerted to potential illegal conduct. 
18. 
Appendix F of the BSA Manual includes examples of suspicious transactions that 
may indicate money laundering, terrorist financing, or fraud, including: 
a. 
Funds transfer activity is unexplained, repetitive, or shows unusual patterns; 
b. 
The currency transaction patterns of a business show a sudden change 
inconsistent with normal activities; 
c. 
Unusual transfers of funds occur among related accounts or among accounts 
that involve the same or related principals; 
d. 
Currency is deposited or withdrawn in amounts just below identification or 
reporting thresholds; 
e. 
Regarding nonprofit or charitable organizations, financial transactions 
occur for which there appears to be no logical economic purpose or in which 
there appears to be no link between the stated activity of the organization 
and the other parties in the transaction; 
f. 
Funds are sent or received via international transfers from or to higher-risk 
locations. 
19. 
In addition, the CICO Act, 14 V.I.C. § 600, incorporates violations of Virgin Islands 
2 Id. at 2. 
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Law and federal felonies, which includes the BSA's criminal-liability provisions. 
II. 
Jeffrey Epstein's Criminal Conduct 
20. 
Jeffrey Epstein was a resident of the Virgin Islands. 
21. 
In 2008, Epstein pled guilty to one count of solicitation of prostitution with a minor 
in Palm Beach, Florida. As a result of that conviction, Epstein was forced to register as a sex 
offender in the Virgin Islands. 
22. 
Epstein was a Tier 1 offender under Virgin Islands law based upon his Florida 
conviction of procuring a minor for prostitution. 
23. 
On January 15, 2020, the Government filed a lawsuit against Jeffrey Epstein's 
estate and related individuals and entities for violation of the CICO Act, 14 V.I.C. §§ 600 to 614, 
and civil conspiracy, which the Government recently settled. As laid out in the Government's 
Second Amended Complaint, ST-20-CV-14, ("SAC") (attached as Exhibit I), Epstein created a 
network of companies and individuals who participated in, directly or indirectly, and conspired with 
him in a pattern of criminal activity related to the sex trafficking, forced labor, sexual assault, child 
abuse, and sexual servitude of these young women and children. SAC
 43-75. Epstein and his 
associates trafficked underage girls to the Virgin Islands, held them captive, and sexually abused 
them, causing them grave physical, mental, and emotional injury. Id. 
24. 
To accomplish this criminal activity, Epstein formed an association in fact with 
both companies and non-profit organizations that he owned and operated, as well as individuals, 
who were willing to participate in, directly or indirectly, facilitate, and conceal Epstein's criminal 
activity in exchange for Epstein's bestowal of financial and other benefits, including sexual 
services and forced labor from victims. Id.
 at 157-195. 
25. 
In October 2012, the Southern Trust Company—one of the companies Epstein 
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owned—applied for economic benefits from the Virgin Islands Economic Development 
Commission ("EDC") so the company could provide "cutting edge consulting services" in the area 
of "biomedical and financial in formatics."Id.11 157-158. Southern Trust Company received a 10-
year package of economic incentives running from February 1, 2013 until January 31, 2023 that 
included a 90% exemption from income taxes and 100% exemptions from gross receipts, excise, 
and withholding taxes in the Virgin Islands. Id. ¶ 159. 
26. 
Southern Trust, in fact, appeared to perform no informatics or data-mining services 
during this period. Instead, Southern Trust funded the Epstein Enterprise (defined below), acting as 
a conduit for payment to foreign women, credit cards, airplanes and other instrumentalities. Id. 
11 167-173. 
27. 
This illicit association of Epstein, businesses, and his associates constitutes what is 
referred to herein as the "Epstein Enterprise." Specifically included in the Epstein Enterprise were 
the following companies and non-profit organizations, all of which had accounts with JP Morgan: 
2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, 
Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, 
LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 
28. 
Epstein used his wealth and power to create the Epstein Enterprise, which engaged 
in a pattern of criminal activity by repeatedly procuring and subjecting underage girls and young 
women to unlawful sexual conduct, sex trafficking, and forced labor. 
29. 
Many of these women, particularly after Epstein's conviction in 2008, were 
trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, 
these women were recruited and, in several instances, required to many other Epstein victims in 
order to maintain their immigration status and their availability to Epstein. Id. f[ 62- 63, 78, 86. 
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30. 
As also alleged in the Second Amended Complaint, recruiters and victims were paid 
in cash or through entities set up by Epstein and/or his associates. Id. 1 100. Many of these companies 
were shell companies, that existed merely to transfer money to other accounts, or to shelter Epstein's 
assets from judgment. Id. 1 116. 
31. 
Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co-
Executors of Epstein's Estate, authorized or directed many of the transactions in JP Morgan accounts 
held by Epstein or related entities. /c/.11 8-10, 76-117. 
32. 
Epstein and the Epstein Enterprise continued trafficking and sexually abusing 
young women and female children until Epstein was arrested by federal law enforcement 
authorities on July 6, 2019 on federal charges for the sex trafficking of minors. 
33. 
Epstein was found dead on August 10, 2019 while in custody in a federal detention 
center in New York on charges for sex-trafficking crimes. Id. 1 7. 
ALLEGATIONS 
I. 
Jeffrey Epstein Was an Extremely High-Risk Customer 
34. 
Jeffrey Epstein's reputation as a sex trafficker and abuser of women and girls was 
well-known and well-publicized for more than a decade before his death. 
35. 
Between 2005 and 2013, there were numerous press reports that Epstein sexually 
abused women and girls. 
36. 
In March 2005, there were press reports that Epstein paid a 14-year old girl in Palm 
Beach, Florida for a "massage" and then molested her. Following these allegations, multiple 
underage girls, many of them high school students, told police that Epstein also hired them to give 
sexual massages. 
37. 
Throughout 2006—when Epstein was arrested in Palm Beach, Florida for 
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solicitation of a minor—there was extensive press regarding the nature and extent of Epstein's 
sexual offenses, including the existence of dozens of victims. 
38. 
In 2008, Epstein pled guilty to sexual offenses in Palm Beach, Florida, including 
solicitating a minor for prostitution. Epstein was sentenced to 18 months in jail and was required 
to register as a sex offender. 
39. 
In 2009, the non-prosecution agreement between Epstein and the United States 
became public. It revealed allegations that Epstein may have used interstate commerce to induce 
minors to engage in prostitution, engaged in illicit sexual conduct with minors, and trafficked 
minors. 
40. 
In 2010, press reports noted allegations that Epstein was involved with Eastern 
European women in particular and that a modeling agency he helped fund brought "young girls . . 
. often from Eastern Europe" to the United States on Epstein's private jets.;
II. 
JP Morgan Knew Epstein Was a Felon, Registered Sex Offender, and Alleged Child 
Trafficker 
41. 
JP Morgan did business with Jeffrey Epstein from as early as 1998 to 2013. In that 
time. JP Morgan serviced approximately fifty-five Epstein-related accounts collectively worth 
hundreds of millions of dollars. 
42. 
On information and belief, based on the Government's review of financial records, 
information from and regarding victims of Epstein's trafficking, and other publicly available 
information, at least 20 individuals paid through JP Morgan accounts were victims of trafficking 
and sexual assault in Little St. James, New York, and/or other Epstein properties. These women 
were trafficked and abused during different intervals between at least 2003 and July 2019, when 
3 Conchita Samoff, Jeffrey Epstein Pedophile Billionaire and His Sex Den, The Daily Beast (July 
22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 
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Epstein was arrested and jailed, and these women received payments, typically multiple payments, 
between 2003 and 2013 in excess of $1 million collectively. Epstein also withdrew more than 
$775,000 in cash over that time frame from JP Morgan accounts, especially significant as Epstein 
was known to pay for "massages," or sexual encounters, in cash. Financial information also 
reflects payments drawn from JP Morgan accounts of nearly $1.5 million to known recruiters, 
including to the MC2 modeling agency, and another $150,000 to a private investigative firm. 
43. 
JP Morgan knew early on that Epstein was an extremely high-risk client but 
decided, at multiple points during the relationship, to continue servicing Epstein's accounts 
because of his vast wealth and connections with other high net worth individuals. 
44. 
In 2006, JP Morgan's Global Corporate Security Division found "[s]everal 
newspaper articles . . . that detail the indictment of Jeffrey Epstein in Florida on felony charges of 
soliciting underage prostitutes." At that time, JP Morgan decided to continue doing business with 
Epstein but concluded his account "should be classified as high risk" and require special approval. 
45. 
In a 2010 internal email, JP Morgan's risk management division discussed new 
allegations against Epstein: "See below new allegations of an investigation related to child 
trafficking — are you still comfortable with this client who is now a registered sex offender." 
Another JP Morgan employee responded: "In my short tenure working on the account these stories 
pop up including these from the summer." 
46. 
In January 2011, JP Morgan's AML compliance director requested re-approval for 
the bank's relationship with Epstein from JP Morgan's then-General Counsel "in light of the new 
allegations of human trafficking . ." Another JP Morgan employee responded: "I thought we did 
that in approving a $50 million new line of credit last month?" 
47. 
In JP Morgan's January 2011 review of Epstein's accounts, the bank concluded 
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there were "no material updates" but noted: 
A few news stories during 2010 connects Jeffrey Epstein to human trafficking. The 
coverage team . . . all met to discuss the situation and agreed to enhance monitoring 
and document a discussion with the client. Jes Staley discussed the topic with 
Jeffrey Epstein who replied there was no truth to the allegations, no evidence and 
was not expecting any problems. We will continue to monitor the accounts and cash 
usage closely going forward. 
48. 
In March 2011, JP Morgan's Global Corporate Security Division reported: 
"Numerous articles detail various law enforcement agencies investigating Jeffrey Epstein for 
allegedly participating, directly or indirectly, in child trafficking and molesting underage girls. 
Jeffrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding solicitation 
for an undisclosed amount." The report also identified the following "derogatory information": 
a. "Jean Luc Brunel, owner of MC2 Model Management and Jeffrey Epstein 
engaged in racketeering that involved luring in minor children for sexual play for 
money. In addition, Brunel was a frequent passenger on Epstein's private jet and 
often visited Epstein in jail." 
b. "MC2 Model Management received $1 million from Epstein in 2005. It is 
unknown if the money was given as a secret investment or payment for services 
as a procurer." 
49. 
In August 2011, when conducting a Know-Your-Customer review, JP Morgan 
flagged an account relating to Ghislaine Maxwell—Epstein's former companion who recently was 
sentenced to 20 years in prison for conspiring with Epstein to sexually abuse minors. Maxwell 
wanted to set up an account for her "personal recruitment consulting business." In an internal 
email, JP Morgan's AML Director asked: "What does she mean by personal recruitment?? Are 
you sure this will have nothing to do with Jeffrey? If you want to proceed, I suggest that we flag 
this as a High Risk Client." 
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50. 
In 2013—the year that JP Morgan terminated its relationship with Epstein—JP 
Morgan flagged in Epstein's history that "[p]er bank policy, felons [like Epstein] are considered 
high risk and require additional approval." 
51. 
JP Morgan's banking relationship with Epstein was known at the highest levels of 
the bank. For instance, an August 2008 internal email states, "I would count Epstein's assets as a 
probable outflow for '08 ($120mm or so?) as I can't imagine it will stay (pending Dimon review)." 
III. 
Head of JP Morgan's Private Bank Had Close Personal Relationship With Epstein 
52. 
Former senior executive, Jes Staley ("Staley"), developed a close relationship with 
Epstein when Staley was the head of JP Morgan's Private Bank, which is a segment of JP Morgan's 
business dedicated to extremely wealthy clients with at least $10 million in assets. 
53. 
Between 2008 and 2012, Staley exchanged approximately 1,200 emails with 
Epstein from his JP Morgan email account. These communications show a close personal 
relationship and "profound" friendship between the two men and even suggest that Staley may 
have been involved in Epstein's sex-trafficking operation. They also reveal that Staley 
corresponded with Epstein while Epstein was incarcerated and visited Epstein's Virgin Islands 
residence on multiple occasions. Epstein even advised Staley in connection with Staley's salary 
negotiations at JP Morgan in July of 2008. 
54. 
On December 30, 2008, Epstein and Staley discussed via email Staley's visit to 
Epstein's residence in Palm Beach, Florida. Epstein wrote that he would not be home the following 
Sunday, but that Staley was welcome to use the house. Staley replied that he would instead make 
arrangements to visit Epstein in Palm Beach in early January. On January 8, 2009—around the 
time of Staley's scheduled visit to Palm Beach—Epstein wired $2,000 from his JP Morgan account 
to a woman with an Eastern European surname. 
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55. 
Between August 27 and 29, 2009, Staley communicated via email to Epstein that 
he would be in London in a week. Epstein inquired whether Staley would need anything while in 
London, and Staley replied, "Yep." On August 31, 2009, Epstein wired $3,000 from his JP Morgan 
account to the same Eastern European woman Epstein paid in January 2009. 
56. 
Staley sent an email to Epstein on November 1, 2009, when Epstein was 
incarcerated and Staley was presumably visiting Little St. James, saying: 
So when all hell breaks lo[o]se, and the world is crumbling, I will come here, and 
be at peace. Presently, I'm in the hot tub with a glass of white wine. This is an 
amazing place. Truly amazing. Next time, we're here together. I owe you much. 
And I deeply appreciate our friendship. I have few so profound. 
57. 
On December 4, 2009, Staley told Epstein via email: "I realize the danger in 
sending this email. But it was great to be able, today, to give you, in New York City, a long 
heartfelt, hug." 
58. 
The next day, Epstein wrote to Staley, "you were with Larry, and I had to put up 
with . . ." and attached a picture of a young woman (shown below). Staley quipped, "don't tell me 
a French wine." Epstein replied, "always thoughts of alcohol." 
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59. 
On December 20, 2009, Epstein sent an email to Staley that was blank except for a 
picture of a young woman (shown below). 
60. 
On January 15, 2010, Staley emailed Epstein, referring to Little St. James, "Arrived 
at your harbor. Someday, we have to do this together." 
61. 
In July 2010, Staley sent an email to Epstein, saying: "Maybe they're tracking u? 
That was fun. Say hi to Snow White." Epstein responded: "[W]hat character would you like next?" 
When Staley said "Beauty and the Beast", Epstein replied: "well one side is available." 
62. 
None of the emails between Epstein and Staley were flagged in connection with 
risk reviews of Epstein's accounts. Moreover, JP Morgan allowed Staley to remain a decision-
maker on Epstein's accounts. JP Morgan even tasked Staley to discuss the human trafficking 
allegations with Epstein. 
63. 
In July 2013—several months after Staley left JP Morgan to join another financial 
institution—JP Morgan's Compliance Officer terminated JP Morgan's relationship with Epstein. 
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64. 
At the time of Epstein's death in 2019, Staley was the Chief Executive Officer of 
Barclays; however, Staley stepped down from that position in November 2021 after British 
financial regulators concluded an investigation into Staley's characterization of his relationship 
with Epstein. 
IV. 
o Morgan Ignored Obvious Red Flags Relating to Epstein's Accounts 
65. 
Despite JP Morgan's claims that it would closely monitor Epstein's accounts, JP 
Morgan ignored numerous red flags related to Epstein's accounts and failed to comply with federal 
banking regulations. 
66. 
Between 2003 and 2013, Epstein and/or his associates used Epstein's accounts to 
make numerous payments to individual women and related companies. Among the recipients of 
these payments were numerous women with Eastern European surnames who were publicly and 
internally identified as Epstein recruiters and/or victims. For example, Epstein paid more than 
$600,0000 to Jane Doe I, a woman who—according to news reports contained in JP Morgan's due 
diligence reports-Epstein purchased at the age of 14. Like other women who received payments 
from Epstein, Jane Doe 1 listed Epstein's apartments on 66th Street in New York City as her 
address, which should have been a red flag to JP Morgan. 
67. 
Epstein and/or his associates also made significant cash withdrawals and 95 foreign 
remittances with no known payee. For example, Hyperion Air, Inc.—the Epstein-controlled 
company that owned Epstein's private jet—issued over $547,000 in checks payable to cash 
purportedly for "fuel expenses when traveling to foreign countries." Additionally, between January 
2012 and June 2013, Hyperion converted more than $120,000 into foreign currency. Many of these 
cash withdrawals either exceeded the $10,000 reporting threshold or were seemingly structured to 
avoid triggering the reporting requirement. This is particularly significant since it is well known 
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that Epstein paid his victims in cash. SAC1 100. 
68. 
In addition, Epstein and/or his representatives appeared to be misusing JP Morgan 
accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and 
Enhanced Education. Epstein made payments from these accounts with no clear nexus to the 
organization's charitable purpose. For example, Epstein and/or his representative used the 
C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known 
victims, and over $20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or 
his representative used the Enhanced Education fund to pay $124,232 to 
and 
$15,000 to 
and 
, a firm owned by Epstein's reportedly prior 
girlfriend. 
69. 
Each of these red flags was serious; together, they suggest a pattern of potentially 
illegal conduct that should have prompted action by JP Morgan. Despite this, JP Morgan's 2013 
compliance report describes "nothing unusual" in Epstein's account transactions, confirms that 
Epstein's transaction activity appears "reasonable, normal, and expected for the type of business 
or industry in which the client engages", and denies that any "unusual. . . activity" was detected, 
noting that "Compliance reviews activity regularly." Moreover, the frequency of Epstein's 
payments and the fact that the vast majority of account activity was payments to women and cash 
withdrawals rather than business activity should have been enough to trigger action. 
70. 
Even as late as May 2013—mere months before JP Morgan terminated Epstein's 
account—JP Morgan provided lines of credit to Epstein of up to $50 million. 
V. 
Epstein Brought Additional High Net Worth Clients to JP Morgan 
71. 
In addition to his own holdings with JP Morgan, Epstein helped, or promised to 
help, Staley recruit ultrawealthy clients to JP Morgan. A few examples are laid out below. 
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72. 
In 2004, Epstein introduced Staley to Glenn Dubin, the owner of Highbridge 
Capital Management—one of the country's largest hedge funds. This laid the groundwork for JP 
Morgan's acquisition of Highbridge—a move that helped catapult Staley's career. 
73. 
In 2011, Epstein and Staley had extensive discussions regarding the creation of a 
"very HIGH profile" donor advised fund ("DAF"), which is an investment account established to 
support charitable organizations, headed by the 
Epstein pitched the 
DAF 
as an "exclusive club" with a minimum $100 million donation where JP Morgan would act as the 
fiduciary. 
VI. 
JP Morgan's 
Reveals Systematic Failures 
74. 
75. 
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76. 
Further, it does not appear from the Government's investigation that JP Morgan 
engaged in any investigation of the source of Epstein's funds. For example, in 2012, an internal 
email from JP Morgan identified the following questions for Epstein regarding his account activity: 
QUESTION: For checking account: 
Review the activity for the period overall and explain how the client's transactions 
profile agrees with or doesn't agree with expectations for the client based on the 
client relationship (purpose of accounts, occupation, business activity, etc.[)] 
Compliance reviewed regularly 
Questions for Asset/brokerage Account: 
What is the purpose/intended use of the account(s)? Please provide a detailed 
description of how the Client Direct Asset/Brokerage Account(s) will be used by 
the client. 
Investments/trading/wealth accumulation 
**Review the activity for the period overall and explain how the client's transaction 
profile agrees with or doesn't agree with expectations for the client based on the 
client relationship (purpose of accounts, occupation, business activity, etc.): 
Compliance reviewed regularly 
Yet, there is no evidence that JP Morgan pursued or received a response from Epstein even though 
JP Morgan was required to conduct this minimum level of due diligence pursuant to 31 C.F.R. 
§ 1010.620(b)(3). 
77. 
JP Morgan also seemingly did no due diligence on the nature of the various business 
entities for which it held accounts for Epstein, which appear to have no legitimate business purpose 
and, upon information and belief, were part of Epstein's criminal enterprise in the Virgin Islands. 
78. 
In January 2013—the year JP Morgan terminated Epstein's accounts—the Office 
of the Comptroller of the Currency ("OCC") entered into a consent order with JP Morgan regarding 
deficiencies in the bank's overall program for BSA/AML compliance. The OCC found—
consistent with the Government's findings here—that JP Morgan failed to develop adequate due 
diligence on customers and failed to comply with federal banking regulations. In fact, the OCC 
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noted that JP Morgan "failed to identify significant volumes of suspicious activity"! 
79. 
After JP Morgan terminated Epstein's accounts, Epstein moved his accounts to 
Deutsche Bank from 2013 to 2018. 
80. 
The New York State Department of Financial Services ("NYSDFS") investigated 
Deutsche Bank for failures to monitor Epstein's accounts. On July 6, 2020, the NYSDFS and 
Deutsche Bank entered into a Consent Order with a $150 million penalty, which stated, in relevant 
parts: 
a. 
"The Bank's fundamental failure was that, although the Bank properly 
classified Mr. Epstein as high-risk, the Bank failed to scrutinize the activity 
in the accounts for the kinds of activity that were obviously implicated by 
Mr. Epstein's past. The Bank was well aware not only that Mr. Epstein had 
pled guilty and served prison time for engaging in sex with a minor but also 
that there were public allegations that his conduct was facilitated by several 
named co-conspirators. Despite this knowledge, the Bank did little or 
nothing to inquire into or block numerous payments to named co-
conspirators, and to or on behalf of numerous young women, or to inquire 
how Mr. Epstein was using, on average, more than $200,000 per year in 
cash." 
b. 
"Whether or to what extent those payments or that cash was used by Mr. 
Epstein to cover up old crimes, to facilitate new ones, or for some other 
purpose are questions that must be left to the criminal authorities, but the 
fact that they were suspicious should have been obvious to Bank personnel 
NYSDFS Consent Order at 2-4 (Jan. 14, 2013), https://www.occ.treas.govinews-
issuances/news-releases/2013/nr-occ-2013-8a.pdf. 
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