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at various levels. The Bank's failure to recognize this risk constitutes a 
major compliance failure." 
c. 
"These errors are unacceptable in the context of a major international bank 
and inexcusable in the context of the heightened scrutiny that should have 
occurred in the monitoring of a high-risk customer." 
81. 
The NYSDFS also found fault with Deutsche Bank's failure to obtain answers 
regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 
2018 email, a compliance officer submitted an inquiry . . . about payments to the accounts of 
women with Eastern European surnames at a Russian bank, and asking for an explanation of the 
purpose of the wire transactions and Epstein's relationship with the counterparties."5
82. 
JP Morgan's failures to appropriately monitor Epstein's accounts and comply with 
federal banking regulations are even more egregious than Deutsche Bank's failures because JP 
Morgan failed to demonstrate even basic due diligence and continued its relationship with Epstein 
for over a decade, despite the glaring indications of criminal activity. 
83. 
84. 
So, too, was JP Morgan's decision to allow Jes Staley to serve as an investigator 
and decision-maker with respect to Epstein's accounts, despite glaring red flags regarding Staley's 
relationship with Epstein, was a blatant failure of compliance. 
VII. JP Morgan Fraudulently Concealed Its Continuing Violations 
85. 
JP Morgan's continuous illegal conduct has caused repeated and continuous injury. 
5 Id. at 15. 
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86. 
JP Morgan knew—including at the highest level of the bank—that Epstein was an 
extremely high-risk client. Between 2005 and 2013, there were myriad reports that Epstein 
sexually abused women and girls. In 2008, Epstein pled guilty to sexual offenses and registered as 
a sex offender. Despite JP Morgan's acknowledgement that it needed to closely monitor Epstein, 
JP Morgan ignored numerous red flags and failed to comply with federal banking regulations until 
years later after JP Morgan was no longer benefiting from Epstein's business. 
87. 
JP Morgan also engaged in a course of conduct aimed at fraudulently concealing 
its illegal conduct, including by failing to timely comply with federal banking regulations in order 
to profit from Epstein's wealth and connections. 
88. 
A key purpose of federal banking regulations is to give law enforcement real-time 
information so that it can act to detect violations of the law and protect public safety. 
89. 
The Government of the Virgin Islands did not know, and could not have known, 
that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind 
eye to unusual cash transactions and wires and failed to carry out or follow up on basic due 
diligence and to timely comply with federal banking regulations, as required by the law. 
90. 
Over more than a decade, JP Morgan clearly knew it was not complying with 
federal regulations in regard to Epstein-related accounts as evidenced by its too-little too-late 
efforts after Epstein was arrested on federal sex trafficking charges and shortly after his death, 
when JP Morgan belatedly complied with federal law. 
91. 
The continued illegal conduct by JP Morgan has caused repeated and continuous 
injury. JP Morgan's illegal conduct was not completed nor were all damages incurred until the 
wrongdoing ceased in August 2019 when JP Morgan began belatedly complying with federal 
banking regulations in regard to Epstein-related accounts. 
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VIII. Additional Factual Allegations Regarding JP Morgan's Obstruction 
Conduct 
92. 
In 2006, a JP Morgan Rapid Response Team noted that Epstein "routinely" made 
cash withdrawals in amounts from $40,000 to $80,000 several times per month, totaling over 
$750,000 per year. 
93. 
In addition, Mary Erdoes admitted in her deposition that JP Morgan was aware by 
2006 that Epstein was accused of paying cash to have underage girls and young women brought 
to his home. 
94. 
In the years that followed, JP Morgan employees, including senior executives, 
emailed internally that Epstein was under investigation or had been sued for trafficking or sexual 
abuse. This includes an email in 2010 between Mary Erdoes and Jes Staley regarding a federal 
investigation of Epstein for child trafficking; a 2011 email summarizing a few 2010 news stories 
connecting Epstein to human trafficking and promising to "monitor the accounts and cash usage 
closely going forward;" and a 2011 compliance memo noting that "[n]umerous articles detail 
various law enforcement agencies investigating Jeffrey Epstein for allegedly participating in child 
trafficking and molesting underage girls" and that "Epstein had settled a dozen civil lawsuits out 
of court from his victims regarding solicitation for an undisclosed amount." Internal emails also 
questioned who Epstein's clients were, circulating an article regarding whether Epstein was 
running a Ponzi scheme. 
95. 
Indeed, Epstein's behavior was so widely known at JPMorgan that senior 
executives joked about Epstein's interest in young girls. In 2008, for example, Mary Erdoes 
received an email asking her whether Epstein was at an event "with miley cyrus." 
96. 
In her deposition, Mary Erdoes testified that JP Morgan terminated Epstein as a 
customer in 2013 after she became aware that the withdrawals were "actual cash." However, 
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Epstein had made substantial cash withdrawals every year he banked with JP Morgan, including 
more than $800,000 per year in 2004 and 2005. 
97. 
The cash activity continued in the years after Epstein's plea, though JP Morgan 
accepted, without proof, that the cash was for fuel and landing fees associated with Epstein's 
planes (even during the years when Epstein was incarcerated or under house arrest). Ms. Erdoes 
has rightly dismissed this explanation. 
98. 
In 2010, JP Morgan compliance officials decided that Epstein "should go." One 
senior compliance official reviewing JP Morgan's information on Epstein in 2011 declared that 
there was: "Lots of smoke. Lots of questions." This included that: 
• 
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." 
• 
"whether 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 
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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, 
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." 
99. 
One internal document describes the account of Epstein's "assistant or young lady 
he brought over from Prague (or some place like that)," clearly referring to Jane Doe 1. The 
document describes charges in New York, Palm Beach, and St. Thomas for lingerie and other 
sexually explicit material. Elsewhere, JP Morgan describes media reports referring to the fact that 
Epstein purchased her at age 14. She remained a customer of JP Morgan, and Epstein paid her 
more than $600,000, from his accounts at JP Morgan, including more than $165,000 after Epstein's 
plea. A recruiter given immunity through Epstein's non-prosecution agreement was paid more 
than $728,000 from Epstein's JP Morgan accounts, virtually all of it after the same Florida 
conviction. Epstein also transferred more than $23 million dollars to Ghislaine Maxwell between 
1999 and 2002. 
100. 
Concerns about the risks that Epstein posed were well known enough that numerous 
JP Morgan senior executives, including Steven Cutler, Mary Erdoes, Catherine Keating, and Jes 
Staley met in various groupings in July and October 2008, January 2011, August 2011, and July 
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2013. 
101. 
This is so even though memos from compliance meetings specifically referenced 
articles regarding a federal investigation into "whether a modeling agency run by a friend .. . fed 
his appetite for underage foreign girls" and noted that "Epstein was known to fly young women 
from Eastern Europe to Palm Beach where they'd massage him, among other services." JP 
Morgan had information that it knew was directly relevant to the federal investigation of Epstein's 
suspected trafficking, including regarding Epstein's line of credit to the modeling agency and 
payments to Eastern European women, and 
CAUSES OF ACTION 
COUNT ONE 
Participating in a Sex-Trafficking Venture 
Violation of Trafficking Victims Protection Act 
18 U.S.C. §§ 1591(a)(2), 1595(d) (Parens Patriae) 
102. 
The Government restates and realleges paragraphs Ito 101 of this Complaint as if 
fully set forth herein. 
103. 
The Government brings this Count as parens patriae on behalf of the residents and 
visitors of the United States Virgin Islands and pursuant to the Attorney General's express 
statutory authority. 
104. 
JP Morgan knowingly and intentionally participated in Epstein's sex-trafficking 
venture that was in and affecting interstate and foreign commerce, together and with others, in 
violation of 18 U.S.C. § 1591(a)(2) 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 law. 
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105. 
JP Morgan knowingly and intentionally benefitted financially from and received 
value for its participation in the sex-trafficking venture in which Epstein and his co-conspirators, 
with JP Morgan's knowledge or reckless disregard of the fact, would use means of force, threats 
of force, fraud, coercion, and a combination of such means to sexually abuse young women and 
underage girls, including by causing them to engage in commercial sex acts, in the Virgin Islands 
and elsewhere. 
106. 
Among the financial benefits that JP Morgan received for participating in and 
facilitating Epstein's sex-trafficking venture was the deposit of funds that Epstein—a Virgin 
Islands resident—and Epstein-controlled entities located in the Virgin Islands made to JP Morgan. 
JP Morgan profited from the use of these deposits. Epstein and Epstein-controlled entities located 
in the Virgin Islands deposited these funds in exchange for JP Morgan's facilitation of and 
participation in Epstein's sex-trafficking venture. 
107. 
Also, among the financial benefits that JP Morgan received for participating in and 
facilitating Epstein's sex-trafficking venture were referrals of business opportunities from Epstein 
and his co-conspirators. JP Morgan profited from, or expected to profit from, these referred 
business opportunities. Epstein referred business entities and business opportunities to JP Morgan 
in exchange for its facilitation of and participation in Epstein's sex-trafficking venture. 
108. 
JP Morgan financially profited from the deposits made by Epstein and Epstein-
controlled entities located in the Virgin Islands and from the business opportunities referred to JP 
Morgan by Epstein and his co-conspirators in exchange for its known facilitation of and implicit 
participation in Epstein's sex trafficking venture. 
109. 
JP Morgan knew and recklessly disregarded and concealed the fact that it was 
Epstein's pattern and practice to use the channels and instrumentalities of interstate and foreign 
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commerce to recruit, entice, harbor, transport, provide, obtain, and maintain young women and 
underage girls for purposes of causing them to engage in commercial sex acts in violation of 18 
U.S.C. § 1591(a)(1). 
110. 
JP Morgan and its employees had actual knowledge that they were facilitating 
Epstein's sexual abuse and sex-trafficking conspiracy to recruit, entice, harbor, transport, provide, 
obtain, and maintain young women and underage girls to engage in commercial sex acts through 
the means of force, threats of force, fraud, abuse of process, and coercion. 
III. 
Despite this knowledge, JP Morgan intentionally paid for, concealed, facilitated, 
and participated in Epstein's and his co-conspirators' violations of 18 U.S.C. § 1591(a), which JP 
Morgan knew and was in reckless disregard of the fact that Epstein and his co-conspirators would 
use its bank accounts and financial transactions to coerce, defraud, and force young women and 
underage girls to engage in commercial sex acts. 
112. 
JP Morgan, through its employees and agents and their role in facilitating the 
financial aspect of Epstein's enterprise, actively facilitated or participated in the sex-trafficking 
conspiracy in which Epstein and his co-conspirators led young women and underage girls in the 
Virgin Islands and elsewhere to believe that they would be rewarded if they cooperated with 
Epstein and his co-conspirators and acquiesced to their demands. 
113. 
JP Morgan committed this affirmative conduct knowing or in reckless disregard of 
the fact that Epstein would use cash transactions and financial support provided by JP Morgan as 
a means to defraud, force, and coerce commercial sex acts from young women and underage girls. 
114. 
In addition to having actual knowledge that it was participating in and facilitating 
the Epstein sex-trafficking venture, JP Morgan also knew that it was participating in and 
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facilitating a venture that was engaged in coercive sex trafficking in violation of 18 U.S.C. § 
1591(a)(1). 
115. 
In exchange for facilitating and covering up Epstein's commercial sex trafficking, 
JP Morgan's employees received financial benefits and career advancement from JP Morgan. 
116. 
Facilitating and covering up Epstein's sex trafficking venture was a means for JP 
Morgan employees to obtain economic success and promotion within JP Morgan. 
117. 
JP Morgan's knowing and intentional conduct has caused serious harm to the 
Virgin Islands and its residents, including without limitation financial harm, by facilitating the 
commission of sexual abuse against young women and underage girls, including their engagement 
in commercial sex acts, in the Virgin Islands. 
118. 
JP Morgan's tortious conduct in violating the TVPA was outrageous and intentional 
because it was in deliberate furtherance of a widespread and dangerous criminal sex-trafficking 
venture operated in and from the Virgin Islands. JP Morgan's tortious conduct also evidenced a 
high degree of moral turpitude and demonstrated such wanton disregard for the safety of young 
women and underage girls in the Virgin Islands and elsewhere as to imply a deliberate indifference 
to its legal obligations. 
119. 
By virtue of these knowing and intentional violations of 18 U.S.C. § 1591(a)(2), JP 
Morgan is liable to the Government for all appropriate relief under 18 U.S.C. § 1595(d), including 
damages suffered by the Government and/or Epstein's victims, punitive damages, restitution, 
appropriate injunctive relief, fines, reasonable attorneys' fees, and all such other relief as the Court 
deems appropriate. 
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COUNT TWO 
Criminal Activity—Participating, Directly or Indirectly, in a Sex-Trafficking Venture 
Violation of Trafficking Victims Protection Act, 18 U.S.C. § 1591(a)(2), 
actionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. §§ 604(e) and 605(a) 
120. 
The Government restates and realleges paragraphs 1 to 119 of this Complaint as if 
funny set forth herein. 
121. 
The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail 
criminal activity and lessen its economic and political power in the Territory of the Virgin Islands 
by establishing new penal prohibitions and providing to law enforcement and the victims of 
criminal activity new civil sanctions and remedies." 14 V.I.C. § 601. 
122. 
At all times material herein, JP Morgan was a "person" identified in 14 V.LC. § 
6040). 
123. 
At all times material herein, Epstein and his co-conspirators were engaged in an 
illicit sex-trafficking "enterprise" as defined in 14 V.I.C. § 604(h). 
124. 
At all times material herein, JP Morgan supported and/or was associated with the 
Epstein sex-trafficking enterprise by providing banking and payment-processing services to 
Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or 
incorporated in the Virgin Islands. 
125. 
In providing banking and payment-processing services to Epstein and Epstein-
controlled entities in return for profits realized both from Epstein's and Epstein-controlled entities' 
accounts and from receiving referrals by Epstein of other high-value banking clients, JP Morgan 
knowingly, intentionally, and willfully benefitted financially and by receiving things of value from 
its participation, directly or indirectly, in Epstein's sex-trafficking venture and enterprise, in 
violation of 18 U.S.C. § 1591(a)(2). 
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126. 
JP Morgan's knowing, intentional, and willful receipt of financial benefits and 
things of value from its facilitation and participation in Epstein's sex-trafficking venture and 
enterprise through the financial infrastructure it provided and concealed constitutes a felony under 
18 U.S.C. § 1591(b) and "criminal activity" as defined in 14 V.I.C. § 604(e). 
127. 
By knowingly, intentionally, and willfully receiving financial benefits and things 
of value from its participation, directly or indirectly, via financing in Epstein's sex-trafficking 
venture and enterprise, JP Morgan enabled Epstein to have ready and reliable access to and use of 
resources with which to recruit, entice, harbor, transport, provide, obtain, and maintain young 
women and underage girls for purposes of causing them to engage in commercial sex acts in the 
Virgin Islands and elsewhere. JP Morgan thereby unlawfully conducted and/or participated in, 
directly or indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal 
activity in violation of 14 V.I.C. § 605(a). 
128. 
JP Morgan's illegal activity has caused serious harm to the Virgin Islands and its 
residents, including without limitation financial harm, by facilitating the commission of sexual 
abuse against young women and underage girls, including their facilitation and participation, 
directly or indirectly, in commercial sex acts, in the Virgin Islands. 
129. 
By virtue of this pattern of illegal activity in furtherance of the Epstein sex-
trafficking enterprise, JP Morgan is liable to the Government for all appropriate civil remedies 
under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein's 
victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive 
relief, attorneys' fees and costs, and all such other relief as the Court deems appropriate. 
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COUNT THREE 
Criminal Activity—Willfully Failing To Comply With Federal Banking Law, 
Violation of Bank Secrecy Act. 31 U.S.C. . 5322(a), as it incorporates 
actionable under Virgin Islands 
Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 604(e) and 605(a) 
130. 
The Government restates and realleges paragraphs 1 to 129 of this Complaint as if 
fully set forth herein. 
131. 
The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail 
criminal activity and lessen its economic and political power in the Territory of the Virgin Islands 
by establishing new penal prohibitions and providing to law enforcement and the victims of 
criminal activity new civil sanctions and remedies." 14 V.I.C. § 601. 
132. 
At all times material herein, JP Morgan was a "person" as defined in 14 V.I.C. 
§ 604(1). 
133. 
At all times material herein, Epstein and his co-conspirators were engaged in an 
illicit sex-trafficking "enterprise" as defined in 14 V.I.C. § 604(h). 
134. 
At all times material herein, JP Morgan was employed by and/or associated with 
the Epstein sex-trafficking enterprise by providing banking and payment-processing services to 
Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or 
incorporated in the Virgin Islands. 
135. 
In providing banking and payment-processing services to Epstein and Epstein-
controlled entities, JP Morgan knowingly, intentionally, and willfully failed to comply with federal 
banking regulations in violation of 31 U.S.C. § 5322(a), 
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. From accounts maintained and served at JP Morgan, 
Epstein and Epstein-controlled entities received payments of large dollar amounts for no apparent 
business or other lawful purpose and made repeated cash payments, sometimes in amounts and 
patterns designed to evade federal reporting requirements, to young women and/or underage girls 
who were sexually abused and coerced into engaging in commercial sexual acts in the Virgin 
Islands and elsewhere. 
136. 
JP Morgan's knowing, intentional, and willful failure to comply with federal 
banking regulations constitutes a felony under 31 U.S.C. § 5322(a) and "criminal activity" as 
defined in 14 V.I.C. § 604(e). 
137. 
By knowingly, intentionally, and willfully failing to comply with federal banking 
regulations, JP Morgan enabled Epstein to have ready and reliable access to and use of resources 
with which to recruit, entice, harbor, transport, provide, obtain, and maintain young women and 
underage girls for purposes of causing them to engage in commercial sex acts in the Virgin Islands 
and elsewhere. JP Morgan thereby unlawfully conducted and/or participated in, directly or 
indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal activity 
in violation of 14 V.I.C. § 605(a). 
138. 
JP Morgan's illegal activity has caused serious harm to the Virgin Islands and its 
residents, including without limitation financial harm, by facilitating the commission of sexual 
abuse against young women and underage girls, including their engagement in commercial sex 
acts, in the Virgin Islands. 
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139. 
By virtue of this pattern of illegal activity in furtherance of the Epstein sex-
trafficking enterprise, JP Morgan is liable to the Government for all appropriate civil remedies 
under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein's 
victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive 
relief, attorneys' fees and costs, and all such other relief as the Court deems appropriate. 
COUNT FOUR 
Unfair Methods of Competition 
Violation of Virgin Islands Consumer Fraud 
and Deceptive Business Practices Act, 12A V.I.C. § 304 
140. 
The Government restates and realleges paragraphs 1 to 139 of this Complaint as if 
fully set forth herein. 
141. 
Section 304 of Title 12A of the Virgin Islands Code provides that -[i]t is unlawful 
for any person to engage in unfair methods of competition . . . in the conduct of any trade or 
commerce." 
142. 
JP Morgan is a "person" as defined in 12A V.I.C. § 303(h). 
143. 
JP Morgan's provision of banking services and payment processing for Epstein and 
Epstein-controlled entities constitutes "[t]rade or commerce" as defined in 12 V.I.C. § 303(k). 
144. 
In return for knowingly and intentionally participating in, directly or indirectly, 
facilitating, and concealing by failing to comply with federal banking regulations regarding 
Epstein-related accounts, JP Morgan both profited from the use of the funds in their accounts and 
received referrals of other high-value business opportunities from Epstein and his co-conspirators. 
145. 
By receiving referrals of high-value business opportunities from Epstein and his 
co-conspirators in return for participating in, directly or indirectly, facilitating, and concealing by 
failing to comply with federal banking regulations regarding Epstein-related accounts, JP Morgan 
unlawfully and unjustly enriched itself at the expense of other banks that complied with their legal 
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obligations. This conduct constitutes an unfair method of competition in violation of 12A V.I.C. § 
304. 
146. 
By virtue of its knowing, intentional, and repeated acts constituting unfair 
competition, JP Morgan is liable to the Government for all appropriate civil remedies under 12A 
V.I.C. §§ 328 and 332, including damages, civil penalties awarded on a per-violation basis 
pursuant to 12A V.I.C. § 328(b), appropriate injunctive relief, attorneys' fees and costs, and all 
such other relief as the Court deems appropriate. 
COUNT FIVE 
Obstruction of Enforcement of Trafficking Victims Protection Act 
19 U.S.C. §§ 1591(d), 1595(d) (Parens Patriae) 
147. 
The Government restates and realleges paragraphs 1 to 146 of this Complaint as if 
fully set forth herein. 
148. 
The Government brings this Count as parens patriae on behalf of the residents and 
visitors of the United States Virgin Islands and pursuant to the Attorney General's express 
statutory authority. 
149. 
JP Morgan and its officers and employees knowingly and intentionally obstructed, 
attempted to obstruct, interfered with, and prevented the enforcement of 18 U.S.C. §§ 1591(a)(1) 
& (a)(2), all in violation of 18 U.S.C. § 1591(d). This activity is hereinafter referred to collectively 
as "obstruction." 
150. 
JP Morgan's obstruction of the enforcement of 18 U.S.C. §§ 1591(a)(1) & (a)(2) 
was forbidden by 18 U.S.C. § 1591(d), and JP Morgan thereby violated Chapter 77, Title 18. JP 
Morgan's obstruction described here and in the preceding paragraph directly, proximately, and 
foreseeably harmed women and girls in the Virgin Islands by directly resulting in them being 
caused to engage in commercial sex acts and in other ways. 
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151. 
The United States Department of Justice (including the U.S. Attorney's Offices for 
the Southern District of New York and the Southern District of Florida) was investigating 
Epstein's federal criminal liability for violating (among other laws) the TVPA up to and following 
the return of an indictment against Epstein on or about July 8, 2019. On or about that date, the 
U.S. Attorney's Office for the Southern District of New York indicted Epstein (and unnamed 
"associates") for violating the TVPA. Later, on or about July 29, 2020, the same Office indicted 
Epstein's co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be 
abused by Epstein. The federal criminal investigation of Maxwell included investigation of 
possible violations of the TVPA. 
152. 
By providing financing for Epstein's sex trafficking organization from at least 2000 
through about August 2013, and concealing its actions thereafter, JP Morgan obstructed, interfered 
with, and prevented the federal government's enforcement of the TVPA against Epstein. To the 
extent that the federal government was able to ultimately charge Epstein with TVPA violations, 
the filing of these charges was delayed by JP Morgan's actions. Because of that delay, women 
and girls in the Virgin Islands were coercively caused to engage in commercial sex acts. 
153. 
As one example of how JP Morgan obstructed, attempted to obstruct, interfered 
with, and prevented the federal government's enforcement of the TVPA, JP Morgan permitted 
large withdrawals of cash to Epstein and his associates so that the coercive commercial sex acts 
would escape the detection of federal law enforcement and prosecuting agencies. JP Morgan 
permitted these large cash withdrawals to further the Epstein sex-trafficking venture and with the 
purpose of helping Epstein evade criminal liability for violating the TVPA. 
154. 
As another example of how JP Morgan obstructed, attempted to obstruct, interfered 
with, and prevented the federal government's enforcement of the TVPA, JP Morgan did not follow 
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anti-money laundering (AML) and anti-structuring reporting requirements found in the Bank 
Secrecy Act and other laws. These requirements included an obligation that JP Morgan would 
review transactions in Epstein's JP Morgan accounts for a determination of whether they involved 
suspicious transactions. If JP Morgan had observed these requirements imposed by law, then it 
would have prevented many of the subsequent transactions committed by the Epstein sex-
trafficking venture. JP Morgan knowingly did not follow these requirements because it knew that 
doing so would have prevented Epstein's secret cash transactions that were necessary to his sex-
trafficking operation from escaping knowledge of federal investigative and prosecuting agencies. 
Without JP Morgan's cash, women and girls in the Virgin Islands would not have been coercively 
forced to engage in commercial sex acts. 
155. 
As another example of how JP Morgan obstructed, attempted to obstruct, interfered 
with, and prevented the federal government's enforcement of the TVPA. 
156. 
JP Morgan is not protected from liability for 
157. 
JP Morgan's 
about Epstein's sex-trafficking venture, in 
spite of numerous red flags, was wrongful and purposeful. 
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158. 
If JP Morgan had 
the appropriate federal agencies would have been well 
positioned to investigate Epstein's sex-trafficking venture and TVPA violations. JP Morgan's 
obstructed the federal government's ability to investigate 
those TVPA violations, including violations harming women and girls in the Virgin Islands. If JP 
Morgan had 
it would have prevented the continuation of Epstein's 
sex-trafficking venture, which required the ability to secretly use cash to pay of victims. 
159. 
By permitting the large cash withdrawals by and for Epstein and his associates, JP 
Morgan intended and knew that Epstein's coercive commercial sex acts would escape the detection 
of federal law enforcement and prosecuting agencies for some period of time. JP Morgan 
permitted cash withdrawals to further the Epstein sex-trafficking venture and with the purpose of 
helping Epstein evade criminal liability for violating the TVPA. 
160. 
JP Morgan's obstruction, attempted obstruction, interference with, and prevention 
of the enforcement of the TVPA were all done intentionally and knowingly. For example, JP 
Morgan knew that Epstein was high-risk—specifically, high-risk to violate the TVPA through 
continuing criminal sex-trafficking activities. 
161. 
JP Morgan was well aware that Epstein had pleaded guilty and served prison time 
for engaging in sex with a minor—a crime closely connected with sex-trafficking in violation of 
the TVPA. JP Morgan also was well aware that there were public allegations that his illegal 
conduct was facilitated by several named co-conspirators. But JP Morgan concealed from the 
federal government its numerous cash payments to those co-conspirators. JP Morgan continued 
its affirmative conduct of allowing Epstein to access cash so that he could make those cash 
payments to his co-conspirators with knowledge that such cash transactions did not produce a clear 
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paper trail. JP Morgan's intentional conduct obstructed, attempted to obstruct, in many ways 
interfered with, and prevented the enforcement of the TVPA by federal investigators and 
prosecuting agencies. 
162. 
JP Morgan's relationship with Epstein in allowing his sex-trafficking venture to 
access large sums of cash each year went far beyond a normal (and lawful) banking relationship. 
JP Morgan knew, and intended, that its relationship with Epstein would go far beyond a normal 
banking relationship. JP Morgan knew that its decision to go beyond a normal banking 
relationship with Epstein obstructed the ability of federal law enforcement and prosecuting 
agencies to enforce the TVPA. 
163. 
JP Morgan's obstruction of the federal government's TVPA and other law 
enforcement efforts was intentional and willful and, therefore, JP Morgan intentionally and 
willfully caused Epstein's commission of the forcible commercial sex acts with women and girls 
in the Virgin Islands through its obstruction supporting the concealment of Epstein's sex-
trafficking venture. JP Morgan knew that Epstein and his other co-conspirators would use means 
of force, threats of force, fraud, coercion, and a combination of such means to cause women and 
girls, including those in the Virgin Islands, to engage in commercial sex acts. 
164. 
JP Morgan knew and acted in reckless disregard of the fact that its obstruction in 
violation of 18 U.S.C. § 1591(d) would directly and proximately lead to unlawful coercive 
commercial sex acts by Epstein with young women and girls, including those in the Virgin Islands. 
165. 
JP Morgan's obstruction has caused women and girls in the Virgin Islands serious 
harm, including, without limitation, physical, psychological, financial, and reputational harm. 
That harm was directly and proximately caused by the obstruction and the harm resulting from 
obstruction was foreseeable. 
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166. 
JP Morgan's obstruction has caused women and girls in the Virgin Islands harm 
that is sufficiently serious, under all of the surrounding circumstances, to compel a reasonable 
person of the same background and in the same circumstances to perform or to continue 
performing commercial sexual activity in order to avoid incurring that harm. 
167. 
This case does not involve mere fraud. Instead, JP Morgan's criminal conduct in 
obstructing enforcement of the TVPA was outrageous and intentional because it was in deliberate 
furtherance of a widespread and dangerous criminal sex trafficking organization. JP Morgan's 
obstruction also evinced a high degree of moral turpitude and demonstrated such wanton 
dishonesty as to imply a criminal indifference to its legal obligations. JP Morgan's obstruction 
was directed specifically at women and girls, including those in the Virgin Islands, who were the 
victims of Epstein's sex-trafficking organization. 
168. 
JP Morgan has caused serious harm to the Virgin Islands and its residents, including 
without limitation, financial harm, by obstructing federal law enforcement which facilitated the 
commission of sexual abuse against women and girls, including their engagement in commercial 
sex acts, in the Virgin Islands. By virtue of these knowing and intentional violations of 18 U.S.C. 
§ 1591(d), JP Morgan is liable to the Government for appropriate relief under 18 U.S.C. § 1595(d). 
REQUEST FOR RELIEF 
The Government respectfully requests that the Court enter judgment in its favor, and 
against JP Morgan, as follows: 
A. 
That the Court award the Government compensatory, consequential, general, and 
nominal damages, as suffered by the Government and/or Epstein's victims, and 
punitive damages, all against JP Morgan in amounts to be awarded at trial; 
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