EPSTEIN
page 8 / 187 . OCR, unverified
civil lawsuits out of court from his victims regarding solicitation.”22 This made it abundantly clear
to JP Morgan that Epstein was not a one-off offender—he was a prolific, serial abuser of women
and girls that he paid through his many JP Morgan bank accounts.
69.
This same March 2011 report also noted that a company named “MC2 Model
Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children
USVI Complaint, ¶47.
USVI Complaint, ¶47.
USVI Complaint, ¶48.
USVI Complaint, ¶48.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 18 of 53
for sexual play for money,” and that MC2’s owner was a “frequent passenger on Epstein’s private
jet and often visited Epstein in jail.”23 Worse, the report noted that Epstein paid MC2 $1 million
in 2005, and that it was “unknown if the money was given as a secret investment or payment for
services as a procurer.”24
70.
JP Morgan was plainly concerned that Epstein was using his accounts with the Bank
to “procure” ever more victims. This concern within the Bank soon also spread to others within
Epstein’s orbit. Although most of the public learned of Ghislaine Maxwell’s key role in Epstein’s
abuses only after her arrest in 2019, JP Morgan suspected her involvement years earlier. In August
2011, Maxwell applied to open a new account with JP Morgan for a “personal recruitment
consulting business.”25 Internally, 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.”26 While it is unclear how JP Morgan
may have treated Maxwell internally, the Bank plainly did not ever report Maxwell’s suspicious
“recruitment” activities to regulators.
71.
Also in 2011, a senior JP Morgan compliance official who reviewed the Bank’s
relationship with Epstein warned that there was “[l]ots of smoke” and “[l]ots of questions”
surrounding Epstein’s criminal behavior.27 According to the U.S. Virgin Islands’ complaint
against JP Morgan, these included that:
USVI Complaint, ¶48.
USVI Complaint, ¶48.
USVI Complaint, ¶49.
USVI Complaint, ¶49.
USVI Complaint, ¶98.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 19 of 53
Epstein “is alleged to be involved in the human trafficking of young
girls and law enforcement is also allegedly investigating his
involvement in this activity.”
“He is also an alleged personal associate of the CEO of the
Investment Bank (Jes Staley).”
“AML Operations went to a [Private Bank] risk meeting late last
week requesting that we exit this relationship.”
“[W]hether Epstein if further exposed could have a potential serious
impact.”
“The one new concerning thing is the one article about the DOJ
investigation is saying they brought under age girls to the US via a
modeling agency M2 that is owned by a guy named Brunel. Turns
out the banker said today we extended Epstein a loan in relation to
this modeling agency.” The writer claims that the agency is “legit”
and that “it would be hard for us to tell” if “girls were exploited via
their contract or arrangement.” The loan was a letter of credit
provided by JP Morgan to MC2 Model Management.
In 2004, Epstein sponsored private bank accounts and credit cards
for two 18 year olds “that appear to be part of his inner entourage.
One is mentioned in many of the recaps of the escapades as a willing
participant and assistant when hosting visitors. She has received
about 450,000 since opening from Epstein . . . . Both can be put in
Palm Beach during 2004, by way of debit charges, which was when
most allegations were from . . . . He did pay other girls, many models
no huge amounts. Sugar Daddy!”
“His foundation account did pay donations to the Palm Beach Police
Dept as reported just before the case started. The same foundation
account did pay monies direct to models and payments direct to
specialty schools (massage, culinary) and university’s on behalf of
models/aspiring actresses. Nothing was astronomical.”
“His business accounts Fiduciary we saw no client activity. I know
his biggest client, Wexner parted ways when he was convicted. His
[Due Diligence Reports] say he manages a few private clients
money but never says who. I would like to know if in fact he is
managing anyone’s money at this point or is it all his money. We
saw no evidence of disbursements even in the rocky years 08-09.
When the well to do were running to their mattresses, he did not
have any distributions from his accounts at Bear or JP. He does have
money at other institutions so maybe it happened there.”
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 20 of 53