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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. 
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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43. 
44. 
45. 
46. 
47. 
48. 
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01/8223 
6'. 
12 at 123 
49. 
50. 
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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. 
54. 
55. 
56. 
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57. 
58. 
59. 
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 LS at 3.423 
60. 
61. 
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. 
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 
15 
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financial regulators concluded an investigation into Staley's characterization of his relationship 
with Epstein. 
IV. 
JP 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 1, 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 I 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 
that Epstein paid his victims in cash. SAC1 100. 
68. 
In addition, Epstein and/or his representatives appeared to be misusing JP Morgan 
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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 Leslie Wexner 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. 
70. 
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. 
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 
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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. 
76. 
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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 
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 
NYSDFS Consent Order at 2-4 (Jan. 14, 2013), https://www.occ.treas.govrnews-
issuances/news-releases/2013/nr-occ-2013-8a.pdf. 
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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 
at various levels. The Bank's failure to recognize this risk constitutes a 
major compliance failure." 
c. 
"These errors are unacceptable in the context of a major international bank 
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and inexcusable in the context of the heightened scrutiny that should have 
occurred in the monitoring of a high-risk customer." 
81. 
The NYSDFS also found fault with Deutsche Bank's failure to obtain answers 
regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 
2018 email, a compliance officer submitted an inquiry . . . about payments to the accounts of 
women with Eastern European surnames at a Russian bank, and asking for an explanation of the 
purpose of the wire transactions and Epstein's relationship with the counterparties.-5
82. 
JP Morgan's failures to appropriately monitor Epstein's accounts and comply with 
federal banking regulations are even more egregious than Deutsche Bank's failures because JP 
Morgan failed to demonstrate even basic due diligence and continued its relationship with Epstein 
for over a decade, despite the glaring indications of criminal activity. 
83. 
84. 
VII. 
JP Morgan Fraudulently Concealed Its Continuing Violations 
85. 
JP Morgan's continuous illegal conduct has caused repeated and continuous injury. 
86. 
JP Morgan knew—including at the highest level of the bank—that Epstein was an 
extremely high-risk client. Between 2005 and 2013, there were myriad reports that Epstein 
sexually abused women and girls. In 2008, Epstein pled guilty to sexual offenses and registered as 
5 Id. at 15. 
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a sex offender. Despite JP Morgan's acknowledgement that it needed to closely monitor Epstein, 
JP Morgan ignored numerous red flags and failed to comply with federal banking regulations until 
years later after JP Morgan was no longer benefiting from Epstein's business. 
87. 
JP Morgan also engaged in a course of conduct aimed at fraudulently concealing 
its illegal conduct, including by failing to timely comply with federal banking regulations in order 
to profit from Epstein's wealth and connections. 
88. 
A key purpose of federal banking regulations is to give law enforcement real-time 
information so that it can act to detect violations of the law and protect public safety. 
89. 
The Government of the Virgin Islands did not know, and could not have known, 
that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind 
eye to unusual cash transactions and wires and failed to carry out or follow up on basic due 
diligence and to timely comply with federal banking regulations, as required by the law. 
90. 
Over more than a decade, JP Morgan clearly knew it was not complying with 
federal regulations in regard to Epstein-related accounts as evidenced by its too-little too-late 
efforts after Epstein was arrested on federal sex trafficking charges and shortly after his death, 
when JP Morgan belatedly complied with federal law. 
91. 
The continued illegal conduct by JP Morgan has caused repeated and continuous 
injury. JP Morgan's illegal conduct was not completed nor were all damages incurred until the 
wrongdoing ceased in August 2019 when JP Morgan began belatedly complying with federal 
banking regulations in regard to Epstein-related accounts. 
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CAUSES OF ACTION 
COUNT ONE 
Participating in a Sex-Trafficking Venture 
Violation of Trafficking Victims Protection Act 
18 U.S.C. §§ 1591(a)(2), 1595(d) (Parens Patriae) 
92. 
The Government restates and realleges paragraphs 1 to 91 of this Complaint as if 
fully set forth herein. 
93. 
The Government brings this Count as parens patriae on behalf of the residents and 
visitors of the United States Virgin Islands and pursuant to the Attorney General's express 
statutory authority. 
94. 
JP Morgan knowingly and intentionally participated in Epstein's sex-trafficking 
venture that was in and affecting interstate and foreign commerce, together and with others, in 
violation of 18 U.S.C. § 1591(a)(2) 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 law. 
95. 
JP Morgan knowingly and intentionally benefitted financially from and received 
value for its participation in the sex-trafficking venture in which Epstein and his co-conspirators, 
with JP Morgan's knowledge or reckless disregard of the fact, would use means of force, threats 
of force, fraud, coercion, and a combination of such means to sexually abuse young women and 
underage girls, including by causing them to engage in commercial sex acts, in the Virgin Islands 
and elsewhere. 
96. 
Among the financial benefits that JP Morgan received for participating in and 
facilitating Epstein's sex-trafficking venture was the deposit of funds that Epstein—a Virgin 
Islands resident—and Epstein-controlled entities located in the Virgin Islands made to JP Morgan. 
JP Morgan profited from the use of these deposits. Epstein and Epstein-controlled entities located 
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in the Virgin Islands deposited these funds in exchange for JP Morgan's facilitation of and 
participation in Epstein's sex-trafficking venture. 
97. 
Also, among the financial benefits that JP Morgan received for participating in and 
facilitating Epstein's sex-trafficking venture were referrals of business opportunities from Epstein 
and his co-conspirators. JP Morgan profited from, or expected to profit from, these referred 
business opportunities. Epstein referred business entities and business opportunities to JP Morgan 
in exchange for its facilitation of and participation in Epstein's sex-trafficking venture. 
98. 
JP Morgan financially profited from the deposits made by Epstein and Epstein-
controlled entities located in the Virgin Islands and from the business opportunities referred to JP 
Morgan by Epstein and his co-conspirators in exchange for its known facilitation of and implicit 
participation in Epstein's sex trafficking venture. 
99. 
JP Morgan knew and recklessly disregarded and concealed the fact that it was 
Epstein's pattern and practice to use the channels and instrumentalities of interstate and foreign 
commerce to recruit, entice, harbor, transport, provide, obtain, and maintain young women and 
underage girls for purposes of causing them to engage in commercial sex acts in violation of 18 
U.S.C. § 1591(a)(1). 
100. 
JP Morgan and its employees had actual knowledge that they were facilitating 
Epstein's sexual abuse and sex-trafficking conspiracy to recruit, entice, harbor, transport, provide, 
obtain, and maintain young women and underage girls to engage in commercial sex acts through 
the means of force, threats of force, fraud, abuse of process, and coercion. 
101. 
Despite this knowledge, JP Morgan intentionally paid for, concealed, facilitated, 
and participated in Epstein's and his co-conspirators' violations of 18 U.S.C. § 1591(a), which JP 
Morgan knew and was in reckless disregard of the fact that Epstein and his co-conspirators would 
24 
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use its bank accounts and financial transactions to coerce, defraud, and force young women and 
underage girls to engage in commercial sex acts. 
102. 
JP Morgan, through its employees and agents and their role in facilitating the 
financial aspect of Epstein's enterprise, actively facilitated or participated in the sex-trafficking 
conspiracy in which Epstein and his co-conspirators led young women and underage girls in the 
Virgin Islands and elsewhere to believe that they would be rewarded if they cooperated with 
Epstein and his co-conspirators and acquiesced to their demands. 
103. 
JP Morgan committed this affirmative conduct knowing or in reckless disregard of 
the fact that Epstein would use cash transactions and financial support provided by JP Morgan as 
a means to defraud, force, and coerce commercial sex acts from young women and underage girls. 
104. 
In addition to having actual knowledge that it was participating in and facilitating 
the Epstein sex-trafficking venture, JP Morgan also knew that it was participating in and 
facilitating a venture that was engaged in coercive sex trafficking in violation of 18 U.S.C. § 
1591 (a)(1). 
105. 
In exchange for facilitating and covering up Epstein's commercial sex trafficking, 
JP Morgan's employees received financial benefits and career advancement from JP Morgan. 
106. 
Facilitating and covering up Epstein's sex trafficking venture was a means for JP 
Morgan employees to obtain economic success and promotion within JP Morgan. 
107. 
JP Morgan's knowing and intentional conduct has caused serious harm to the 
Virgin Islands and its residents, including without limitation financial harm, by facilitating the 
commission of sexual abuse against young women and underage girls, including their engagement 
in commercial sex acts, in the Virgin Islands. 
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108. 
JP Morgan's tortious conduct in violating the TVPA was outrageous and intentional 
because it was in deliberate furtherance of a widespread and dangerous criminal sex-trafficking 
venture operated in and from the Virgin Islands. JP Morgan's tortious conduct also evidenced a 
high degree of moral turpitude and demonstrated such wanton disregard for the safety of young 
women and underage girls in the Virgin Islands and elsewhere as to imply a deliberate indifference 
to its legal obligations. 
109. 
By virtue of these knowing and intentional violations of 18 U.S.C. § 1591(a)(2), JP 
Morgan is liable to the Government for all appropriate relief under 18 U.S.C. § 1595(d), including 
damages suffered by the Government and/or Epstein's victims, punitive damages, restitution, 
appropriate injunctive relief, fines, reasonable attorneys' fees, and all such other relief as the Court 
deems appropriate. 
COUNT TWO 
Criminal Activity—Participating, Directly or Indirectly, in a Sex-Trafficking Venture 
Violation of Trafficking Victims Protection Act, 18 U.S.C. § 1591(a)(2), 
actionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. §§ 604(e) and 605(a) 
110. 
The Government restates and realleges paragraphs 1 to 109 of this Complaint as if 
funny set forth herein. 
III. 
The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail 
criminal activity and lessen its economic and political power in the Territory of the Virgin Islands 
by establishing new penal prohibitions and providing to law enforcement and the victims of 
criminal activity new civil sanctions and remedies." 14 V.I.C. § 601. 
112. 
At all times material herein, JP Morgan was a "person" identified in 14 V.I.C. § 
604(1). 
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113. 
At all times material herein, Epstein and his co-conspirators were engaged in an 
illicit sex-trafficking "enterprise" as defined in 14 V.I.C. § 604(h). 
114. 
At all times material herein, JP Morgan supported and/or was associated with the 
Epstein sex-trafficking enterprise by providing banking and payment-processing services to 
Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or 
incorporated in the Virgin Islands. 
115. 
In providing banking and payment-processing services to Epstein and Epstein-
controlled entities in return for profits realized both from Epstein's and Epstein-controlled entities' 
accounts and from receiving referrals by Epstein of other high-value banking clients, JP Morgan 
knowingly, intentionally, and willfully benefitted financially and by receiving things of value from 
its participation, directly or indirectly, in Epstein's sex-trafficking venture and enterprise, in 
violation of 18 U.S.C. § 1591(a)(2). 
116. 
JP Morgan's knowing, intentional, and willful receipt of financial benefits and 
things of value from its facilitation and participation in Epstein's sex-trafficking venture and 
enterprise through the financial infrastructure it provided and concealed constitutes a felony under 
18 U.S.C. § 1591(b) and "criminal activity" as defined in 14 V.I.C. § 604(e). 
117. 
By knowingly, intentionally, and willfully receiving financial benefits and things 
of value from its participation, directly or indirectly, via financing in Epstein's sex-trafficking 
venture and enterprise, JP Morgan enabled Epstein to have ready and reliable access to and use of 
resources with which to recruit, entice, harbor, transport, provide, obtain, and maintain young 
women and underage girls for purposes of causing them to engage in commercial sex acts in the 
Virgin Islands and elsewhere. JP Morgan thereby unlawfully conducted and/or participated in, 
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directly or indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal 
activity in violation of 14 V.I.C. § 605(a). 
118. 
JP Morgan's illegal activity has caused serious harm to the Virgin Islands and its 
residents, including without limitation financial harm, by facilitating the commission of sexual 
abuse against young women and underage girls, including their facilitation and participation, 
directly or indirectly, in commercial sex acts, in the Virgin Islands. 
119. 
By virtue of this pattern of illegal activity in furtherance of the Epstein sex-
trafficking enterprise, JP Morgan is liable to the Government for all appropriate civil remedies 
under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein's 
victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive 
relief, attorneys' fees and costs, and all such other relief as the Court deems appropriate. 
COUNT THREE 
Criminal Activity—Willfully Failing To Comply With Federal Banking Law, 
Violation of Bank Secrecy Act, 31 U.S.C. § 5322(a), as it incorporates 
actionable under Virgin Islands 
Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 604(e) and 605(a) 
120. 
The Government restates and realleges paragraphs 1 to 119 of this Complaint as if 
fully set forth herein. 
121. 
The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail 
criminal activity and lessen its economic and political power in the Territory of the Virgin Islands 
by establishing new penal prohibitions and providing to law enforcement and the victims of 
criminal activity new civil sanctions and remedies." 14 V.I.C. § 601. 
122. 
At all times material herein, JP Morgan was a "person" as defined in 14 V.I.C. 
§ 604(1). 
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123. 
At all times material herein, Epstein and his co-conspirators were engaged in an 
illicit sex-trafficking "enterprise" as defined in 14 V.I.C. § 604(h). 
124. 
At all times material herein, JP Morgan was employed by and/or associated with 
the Epstein sex-trafficking enterprise by providing banking and payment-processing services to 
Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or 
incorporated in the Virgin Islands. 
125. 
In providing banking and payment-processing services to Epstein and Epstein-
controlled entities, JP Morgan knowingly, intentionally, and willfully failed to comply with federal 
banking regulations in violation of 31 U.S.C. § 5322(a), 
. From accounts maintained and served at JP Morgan, 
Epstein and Epstein-controlled entities received payments of large dollar amounts for no apparent 
business or other lawful purpose and made repeated cash payments, sometimes in amounts and 
patterns designed to evade federal reporting requirements, to young women and/or underage girls 
who were sexually abused and coerced into engaging in commercial sexual acts in the Virgin 
Islands and elsewhere. 
126. 
JP Morgan's knowing, intentional, and willful failure to comply with federal 
banking regulations constitutes a felony under 31 U.S.C. § 5322(a) and "criminal activity" as 
defined in 14 V.I.C. § 604(e). 
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