EPSTEIN
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JP Morgan had any doubts about the allegations against Epstein in 2006, Epstein’s guilty plea in
2008 erased them.
63.
Internally, Epstein’s guilty plea led some of JP Morgan’s employees to assume that
the Bank would immediately terminate its sprawling relationship with the now-convicted sex
trafficker. But they would be mistaken, as JP Morgan’s senior-most executives decided to
maintain this lucrative, if problematic, relationship. In August 2008, a JP Morgan employee wrote
that she “would count Epstein’s assets as a probable outflow for ’08 ($120mm or so?) as I can’t
imagine it will stay (pending [Jamie] Dimon review).”12
64.
Given that JP Morgan continued to service Epstein’s accounts for at least five more
years, the “Dimon review” evidently resulted in a decision not to take any action against Epstein
following his guilty plea but, rather, to retain the lucrative relationship. The same year, in a
reflection of JP Morgan’s decision to brush off Epstein’s known crimes, Erdoes received an email
asking her whether Epstein was at an event “with miley cyrus”—who was only 16 years old at the
time.13
65.
Press reports about Epstein’s abusive conduct continued to emerge in subsequent
years, and JP Morgan compliance employees continued to express concerns about the Bank’s
Epstein’s full non-prosecution agreement with Florida became public in 2009. This agreement
alleged that Epstein trafficked and engaged in illicit sexual conduct with minors, including across
state lines.
USVI Complaint, ¶51.
USVI Complaint, ¶95.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 16 of 53
continued patronage of someone with Epstein’s history. In 2010, JP Morgan learned of even more
allegations in the press against Epstein, detailing his trafficking of women and minors for abuse.
In an internal email, an employee in JP Morgan’s risk management division referred to “new
allegations of an investigation related to child trafficking,” and asked whether the Bank was “still
comfortable with this client who is now a registered sex offender.”14 Other JP Morgan compliance
employees decided that Epstein “should go.”15 But reflecting the Bank’s fundamental attitude to
Epstein’s crimes, a different JP Morgan risk management employee dismissed these disturbing
reports as routine: “In my short tenure working on the account these stories pop up including these
from the summer.”16
66.
The next year, in January 2011, JP Morgan once again was made keenly aware of
yet more allegations of human trafficking against Epstein. And yet again, JP Morgan brushed off
the allegations. That month, JP Morgan conducted a review of Epstein’s accounts because a “few
news stories during 2010 connect[ed] Jeffrey Epstein to human trafficking.”17 The U.S. Virgin
Islands alleges that JP Morgan’s coverage team “met to discuss the situation and agreed to enhance
monitoring and document a discussion with the client.”18 Unsurprisingly, Defendant Jes Staley—
the CEO of JP Morgan’s Investment Bank who seemingly participated in Epstein’s crimes, as
discussed in Section IV below—was the JP Morgan executive that the Bank entrusted to hold this
“discussion” with Epstein. Also unsurprisingly, Epstein claimed “there was no truth to the
USVI Complaint, ¶45.
USVI Complaint, ¶98.
USVI Complaint, ¶45.
USVI Complaint, ¶46.
USVI Complaint, ¶47.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 17 of 53
allegations” against him and “no evidence.”19 JP Morgan internally concluded that it would
“continue to monitor the accounts and cash usage closely going forward.”20
67.
In other words, JP Morgan knew that Epstein was a convicted sexual offender who
heavily relied on his cash to pay his victims and his associates. JP Morgan also knew that Epstein
regularly withdrew huge amounts of cash from his many accounts with the Bank. Yet JP Morgan’s
response was to simply “monitor” Epstein’s already-extraordinary “cash usage,” rather than take
any measures to report his blatantly suspicious transactions to the authorities. In a hint that Epstein
was too large of a client for JP Morgan to take action against, the Bank had granted Epstein a new
$50 million line of credit only weeks earlier, in December 2010.
68.
Only two months later, JP Morgan’s Global Corporate Security Division internally
circulated even more devastating reports about Epstein’s abuses. In March 2011, this division
reported that “[n]umerous articles detail various law enforcement agencies investigating Jeffrey
Epstein for allegedly participating, directly or indirectly, in child trafficking and molesting
underage girls.”21 Even more damningly, this report also noted that Epstein had “settled a dozen
civil lawsuits out of court from his victims regarding solicitation.”22 This made it abundantly clear