EPSTEIN
page 9 / 187 . OCR, unverified
USVI v. JP Morgan Complaint, ¶98.
72.
Despite unequivocally knowing that Epstein was a serial sex offender, and despite
the obviously suspicious nature of Epstein’s activity with the Bank, JP Morgan took no corrective
action against Epstein for years. Finally, in 2013, JP Morgan terminated its relationship with
Epstein; it continued to do business with him for several years afterward (as detailed below). The
year that JP Morgan terminated Epstein’s accounts, the Bank noted that “[p]er bank policy, felons
are considered high risk and require additional approval.”28 Epstein had been a convicted felon
for almost a decade before his banking accounts were terminated. That the Company left the
accounts in place for so long, despite such deeply troubling, public accounts of his crimes, suggests
either that the Bank’s senior-most executives reviewed and approved Epstein’s ongoing
relationship with the Bank despite knowing about his crimes; or the Bank’s oversight system
failed, allowing Epstein’s abusive conduct to continue unchecked.
IV.
JP MORGAN’S SENIOR-MOST EXECUTIVES SUPERVISED THE BANK’S
RELATIONSHIP WITH EPSTEIN, EVEN YEARS AFTER JP MORGAN
TERMINATED EPSTEIN’S ACCOUNTS
73.
JP Morgan was clearly fully aware of Epstein’s abusive conduct, and its lower-level
employees held deep concerns about the Bank’s ever-deeper relationship with Epstein. But JP
Morgan’s senior-most executives did not share this concern—and this extends far beyond just
Defendant Staley, Epstein’s close friend and apparent fellow abuser (as discussed infra), whom JP
Morgan is now attempting to hold solely responsible for its longstanding failures. Mary Erdoes—
who currently serves as the CEO of JP Morgan’s Asset and Wealth Management division—visited
Epstein at his New York home in both 2011 and 2013. Erdoes is also reported to have exchanged
USVI Complaint, ¶50.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 21 of 53
“dozens of emails” with Epstein, including with regard to a charitable fund that JP Morgan
considered launching together with Epstein.29 Similarly, John Duffy—who served as Vice
Chairman of JP Morgan and as the CEO of JP Morgan’s private bank for ultrawealthy clients—
also visited Epstein at his New York home in April 2013. Just one month later, the private bank
that Duffy ran re-authorized Epstein to borrow money against his accounts, despite JP Morgan’s
compliance officials’ repeated warnings about Epstein’s suspicious practices and criminal
behavior. Another senior JP Morgan executive who worked at the private bank, Justin Nelson,
visited Epstein’s New York home around six times between 2014-2017—after the bank
supposedly terminated Epstein’s accounts. Nelson also visited Epstein at his ranch in New Mexico
in 2016. Defendant Kessler—who was a member of the Board from 1995 to 2007⸺was former
college classmates, close friends and business partners with Epstein’s main benefactor, Leslie
Wexner (“Wexner”), with whom Kessler co-founded a real estate development business. Wexner,
a multibillionaire, has been called Epstein’s “biggest client” and likely helped provide Epstein with
a substantial part of the wealth that enabled his scheme of sexual abuse and predation.
74.
These ties pale in comparison, however, to Defendant Staley’s intimate—and
potentially criminal—relationship with Epstein. Staley led JP Morgan’s Private Banking division
(which was later run by Duffy) from 1999-2001, during which time he formed a close relationship
with Epstein. Staley later served as the CEO of JP Morgan’s Asset Management division from
2001 until 2009, and was then promoted in 2009 to serve as the CEO of JP Morgan’s Investment
Bank. Staley left JP Morgan in 2013: the same year that the bank terminated Epstein’s accounts.
75.
Between 2008 and 2013, Staley used his JP Morgan email account to exchange
some 1,200 emails with Epstein, reflecting the deep bond the two men shared. Some of these
WSJ Article.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 22 of 53
emails suggest that Staley may have participated in or taken advantage of Epstein’s criminal
trafficking operation. In December 2008, for example, Epstein and Staley discussed Staley visiting
Epstein at his residence in Palm Beach. Although Epstein was not going to be in Palm Beach at
the time, Epstein invited Staley to use his house. In early January 2009, around the time that Staley
was staying at Epstein’s house in Palm Beach, Epstein wired $2,000 from his JP Morgan account
to a woman with an Eastern European surname. (Many of the women that Epstein trafficked were
from Eastern Europe).
76.
Later that same year, Epstein and Staley again discussed getting together, this time
in London.30 In late August 2009, Epstein asked Staley whether he would need anything while he