EPSTEIN
page 5 / 1980 . OCR, unverified
4.
Defendant JPMorgan Chase Bank, N.A. is an American multinational investment
bank and financial services company headquartered in New York City and incorporated in
Delaware.
5.
At all relevant times, JP Morgan engaged in business in the Virgin Islands,
including, but not limited to, the acts and practices described herein.
6.
As described below, based on documents reviewed and interviews conducted by
the Government, JP Morgan knowingly facilitated, sustained, and concealed the human trafficking
network operated by Jeffrey Epstein from his home and base in the Virgin Islands, and financially
benefitted from this participation, directly or indirectly, by failing to comply with federal banking
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regulations,
JP Morgan facilitated
and concealed wire and cash transactions that raised suspicion of—and were in fact part of—a
criminal enterprise whose currency was the sexual servitude of dozens of women and girls in and
beyond the Virgin Islands. Human trafficking was the principal business of the accounts Epstein
maintained at JP Morgan.
7.
Upon information and belief, JP Morgan turned a blind eye to evidence of human
trafficking over more than a decade because of Epstein's own financial footprint, and because of
the deals and clients that Epstein brought and promised to bring to the bank. These decisions were
advocated and approved at the senior levels of JP Morgan, including by the former chief executive
of its asset management division and investment bank, whose inappropriate relationship with
Epstein should have been evident to the bank. Indeed, it was only after Epstein's death that JP
Morgan belatedly complied with federal banking regulations regarding Epstein's accounts.
JURISDICTION, VENUE, AND RELATED CASE
8.
This action is brought pursuant to and based on federal and Virgin Islands statutes,
including the federal Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595 ("TVPA"),
and the federal Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336 and its implementing regulations
("BSA").
9.
This Court has federal question subject-matter jurisdiction pursuant to 28 U.S.C.
§ 1331 because the Government's TVPA and BSA-based causes of action arise under federal law.
10.
This Court has supplemental jurisdiction over the Government's Virgin Islands law
claims pursuant to 28 U.S.C. § 1367(a) because these claims are so related to those arising under
or based on federal law as to form part of the same case or controversy under Article III of the
United States Constitution.
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II.
This Court is an "appropriate district court of the United States" in which for the
Government to obtain appropriate relief under 18 U.S.C. § 1595(d) and venue is proper under 28
U.S.C. § 1391(6)(2) because Defendant maintains its principal place of business within this
judicial district, so that this Court may exercise general personal jurisdiction over Defendant, and
because many of the alleged acts and omissions of Defendant giving rise to the Government's
claims took place within this judicial district, so that this Court may exercise specific personal
jurisdiction over Defendant.
12.
Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is
related to Doe I v. JP Morgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because
both actions arise from a common nucleus of operative fact involving Defendant JP Morgan's
alleged participation, directly or indirectly, in Epstein's sex-trafficking venture 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 regulations.
BACKGROUND
I.
JP Morgan's Federal and State Legal Requirements
13.
JP Morgan is subject to federal laws, including the BSA and the Uniting and
Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct
Terrorism Act of 2001, Pub. L. No. 107-56, 115 Stat. 272 ("USA PATRIOT Act"), which amended
certain BSA regulations.
14.
Under both the BSA and USA PATRIOT Act, JP Morgan is required to implement
adequate, risk-based anti-money laundering ("AML") policies and systems to detect and prevent
money laundering or other use of the institution's services to facilitate criminal activities. This
includes, but is not limited to, maintaining a due diligence program, filing suspicious activity
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reports ("SARs") when the financial institutions detect suspicious behavior and currency
transaction reports ("CTRs") for currency transactions or series of currency transactions that
exceed $10,000 in a 24-hour period, preventing structuring or assistance with structuring of