EPSTEIN
page 2 / 187 . OCR, unverified
knowledge and assistance of others within JP Morgan. Mary Erdoes (who has served as CEO of
JP Morgan’s Asset & Wealth Management division) paid numerous visits to Epstein’s home and
has admitted that she and JP Morgan knew of Epstein’s abuses by 2006. Erdoes is known as a top
lieutenant to the Bank’s longtime CEO, Jamie Dimon. And Dimon himself appears to have been
personally involved in sanctioning the Bank’s relationship with Epstein: one August 2008
document references Epstein’s $120 million with JP Morgan being in question “pending Dimon
review.”
5.
Despite this top-to-bottom knowledge, JP Morgan’s Board did nothing. JP Morgan
knew that Epstein was a serial abuser that relied heavily on cash payments, and that Epstein
regularly withdrew vast sums of cash from his JP Morgan accounts. But upon information and
belief, JP Morgan consistently failed to file suspicious activity reports (“SARs”) that it was
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 3 of 53
required to file when it suspected potential criminal activity—as it clearly did. This failure
persisted through Epstein’s entire 15+ year history with the Bank, and persisted for years even
after JP Morgan terminated Epstein’s accounts in 2013. This failure persisted, in fact, through the
time of Epstein’s final arrest in 2019, until which time Epstein continued to commit his prolific
abuses.
6.
This failure to file SARs and otherwise comply with similar anti-money laundering
(“AML”) and know-your-customer (“KYC”) regulations is nothing new for JP Morgan. Rather,
it is a symptom of a broader, years-long failure of governance and oversight by JP Morgan’s board
of directors—a failure for which JP Morgan was previously cited and penalized by regulators, in
2013 and 2014. In 2013, both the OCC and the Federal Reserve accused JP Morgan of failing to
comply with federal AML laws and regulations, including because the Bank failed to file timely
SARs. JM Morgan was hit with a $350 million sanction in 2014 due to its continuing AML
compliance failures. Not only did the Company face civil penalties, it was faced criminal liability
as well: the Bank pleaded guilty in 2014 to two felony counts relating to failures to comply with
AML rules, including the failure to file SARs.
7.
Now, JP Morgan is exposed to substantial legal risk due its role in helping conceal
Epstein’s crimes. One of Epstein’s victims, identified only as “Jane Doe 1”, has brought several
claims (on behalf of herself and other victims) against the Bank for its role in Epstein’s abuse of
her. The government of the U.S. Virgin Islands has also initiated litigation against the Bank for
similar reasons, and is seeking significant monetary damages, including punitive and treble
damages.
8.
All told, JP Morgan has suffered and will continue to suffer substantial monetary
and reputational harm for its longstanding role in assisting the most egregious sex trafficker in
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 4 of 53
modern history. Had JP Morgan’s Board and senior officers taken their oversight responsibilities
seriously, JP Morgan would have consistently reported Epstein’s suspicious practices and would
have terminated its relationship with him much sooner than it actually did. Plaintiff brings this
action on behalf of JP Morgan to hold these directors and officers to account for their longstanding
governance failures.
THE PARTIES
9.
Plaintiff is a stockholder of JP Morgan, and has held JP Morgan stock since 2010.
10.
Nominal Defendant JPMorgan Chase & Co. is a Delaware corporation with its
principal place of business in New York City, New York. JP Morgan’s principal bank subsidiary
is JPMorgan Chase Bank, National Association.
11.
Defendant James Dimon (“Dimon”) has been a director of JP Morgan since 2004.
Dimon has been JP Morgan’s CEO since 2005 and Chairman of the Board since 2006. Dimon is
an individual and is believed to be a resident of New York, New York.
12.
Defendant Ashley Bacon (“Bacon”) has been JP Morgan’s Chief Risk Officer since
2013. Bacon is an individual and is believed to be a resident of Greenwich, Connecticut.
13.
Defendant Linda B. Bammann (“Bammann”) has been a director of JP Morgan
since 2013. Bammann has been Chair of the Risk Committee since 2017, and a member of the
Risk Committee from 2014-2017. Bammann is an individual and is believed to be a resident of
Ocala, Florida.
14.
Defendant James A. Bell (“Bell”) was a JP Morgan director from 2011-2020.
During that time, Bell was a member of the Audit Committee from 2012-2016, and Chair of the
Audit Committee from 2017-2020. Bell is an individual and is believed to be a resident of Beverly
Hills, California.
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