Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 1 of 30
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`UNITED STATES DISTRICT COURT FOR THE
`SOUTHERN DISTRICT OF NEW YORK
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`GOVERNMENT OF THE UNITED
`STATES VIRGIN ISLANDS
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`PLAINTIFF,
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`V.
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`JPMORGAN CHASE BANK, N.A.
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`DEFENDANT.
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`Case Number:
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`ACTION FOR DAMAGES
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`JURY TRIAL DEMANDED
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`COMPLAINT AND DEMAND FOR A JURY TRIAL
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`Plaintiff Government of the United States Virgin Islands (“Government”) files this
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`Complaint against JPMorgan Chase Bank, N.A. (“JP Morgan”) for violations of Trafficking
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`Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and
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`Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and
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`Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges as
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`follows:
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`PARTIES
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`1.
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`The Attorney General of the United States Virgin Islands (hereinafter “Virgin
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`Islands”) brings this parens patriae action on behalf of the Plaintiff, Government of the Virgin
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`Islands, pursuant to 15 U.S.C. § 1595(d) and 3 V.I.C. § 114 and her statutory authority to enforce
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`the laws of the Virgin Islands and protect public safety.
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`2.
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`The Attorney General, pursuant to her authority to represent the Government of the
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`United States Virgin Islands, also acts on behalf of, and with the lawfully delegated authority of,
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`the Virgin Islands Department of Licensing and Consumer Affairs under 12 V.I.C. § 327 in regard
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`to Count Four of the Government’s Complaint alleging violations of the Virgin Islands Consumer
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`1:22-cv-10904-UA
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 2 of 30
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`Fraud and Deceptive Business Practices Act.
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`3.
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`This action stems from an enforcement action the Government filed against the
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`Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey
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`Epstein (“Epstein”), under the Virgin Islands’ Criminally Influenced and Corrupt Organizations
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`Act (“CICO Act”), see Government of the U.S. Virgin Islands v. Indyke et al., Case No. ST-20-
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`CV-14 (Super. Ct. V.I. Jan. 15, 2020). The Attorney General brings this action, after presenting
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`her findings to JP Morgan in September 2022, in her ongoing effort to protect public safety and to
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`hold accountable those who facilitated or participated in, directly or indirectly, the trafficking
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`enterprise Epstein helmed. The investigation revealed that JP Morgan knowingly, negligently, and
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`unlawfully provided and pulled the levers through which recruiters and victims were paid and was
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`indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial
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`institutions can connect—or choke—human trafficking networks, and enforcement actions filed
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`and injunctive relief obtained by attorneys general are essential to ensure that enterprises like
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`Epstein’s cannot flourish in the future.
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`4.
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`Defendant JPMorgan Chase Bank, N.A. is an American multinational investment
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`bank and financial services company headquartered in New York City and incorporated in
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`Delaware.
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`5.
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`At all relevant times, JP Morgan engaged in business in the Virgin Islands,
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`including, but not limited to, the acts and practices described herein.
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`6.
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`As described below, based on documents reviewed and interviews conducted by
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`the Government, JP Morgan knowingly facilitated, sustained, and concealed the human trafficking
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`network operated by Jeffrey Epstein from his home and base in the Virgin Islands, and financially
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`benefitted from this participation, directly or indirectly, by failing to comply with federal banking
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`2
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 3 of 30
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`regulations. JP Morgan facilitated and concealed wire and cash transactions that raised suspicion
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`of—and were in fact part of—a criminal enterprise whose currency was the sexual servitude of
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`dozens of women and girls in and beyond the Virgin Islands. Human trafficking was the principal
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`business of the accounts Epstein maintained at JP Morgan.
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`7.
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`Upon information and belief, JP Morgan turned a blind eye to evidence of human
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`trafficking over more than a decade because of Epstein’s own financial footprint, and because of
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`the deals and clients that Epstein brought and promised to bring to the bank. These decisions were
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`advocated and approved at the senior levels of JP Morgan, including by the former chief executive
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`of its asset management division and investment bank, whose inappropriate relationship with
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`Epstein should have been evident to the bank. Indeed, it was only after Epstein’s death that JP
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`Morgan belatedly complied with federal banking regulations regarding Epstein’s accounts.
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`JURISDICTION, VENUE, AND RELATED CASE
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`8.
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`This action is brought pursuant to and based on federal and Virgin Islands statutes,
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`including the federal Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595 (“TVPA”),
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`and the federal Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336 (“BSA”).
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`9.
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`This Court has federal question subject-matter jurisdiction pursuant to 28 U.S.C.
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`§ 1331 because the Government’s TVPA and BSA-based causes of action arise under federal law.
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`10.
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`This Court has supplemental jurisdiction over the Government’s Virgin Islands law
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`claims pursuant to 28 U.S.C. § 1367(a) because these claims are so related to those arising under
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`or based on federal law as to form part of the same case or controversy under Article III of the
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`United States Constitution.
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`11.
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`This Court is an “appropriate district court of the United States” in which for the
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`Government to obtain appropriate relief under 18 U.S.C. § 1595(d) and venue is proper under 28
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`3
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 4 of 30
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`U.S.C. § 1391(b)(2) because Defendant maintains its principal place of business within this
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`judicial district, so that this Court may exercise general personal jurisdiction over Defendant, and
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`because many of the alleged acts and omissions of Defendant giving rise to the Government’s
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`claims took place within this judicial district, so that this Court may exercise specific personal
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`jurisdiction over Defendant.
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`12.
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` Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is
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`related to Doe 1 v. JP Morgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because
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`both actions arise from a common nucleus of operative fact involving Defendant JP Morgan’s
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`alleged participation, directly or indirectly, in Epstein’s sex-trafficking venture by facilitating
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`payments to women and girls, channeling funds to Epstein to fund the operation, and concealing
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`Epstein’s criminal conduct by failing to comply with federal banking regulations.
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`I.
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`JP Morgan’s Federal and State Legal Requirements
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`BACKGROUND
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`13.
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`JP Morgan is subject to federal laws, including the BSA and the Uniting and
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`Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct
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`Terrorism Act of 2001, Pub. L. No. 107-56, 115 Stat. 272 (“USA PATRIOT Act”).
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`14.
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`Under both the BSA and USA PATRIOT Act, JP Morgan is required to implement
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`adequate, risk-based anti-money laundering (“AML”) policies and systems to detect and prevent
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`money laundering or other use of the institution’s services to facilitate criminal activities. This
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`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
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`transaction reports (“CTRs”) for currency transactions or series of currency transactions that
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`exceed $10,000 in a 24-hour period, preventing structuring or assistance with structuring of
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`4
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 5 of 30
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`transactions undertaken for the purpose of evading federal reporting requirements, and maintaining
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`systems to prevent money laundering.
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`15.
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`The FDIC and the other federal banking regulators, including the Federal Reserve
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`Board and Office of the Comptroller of the Currency, formed an interagency organization known
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`as Federal Financial Institutions Examination Council (“FFIEC”).
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`16.
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`To provide further guidance to banks on what BSA compliance requires, FFIEC
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`published a Bank Secrecy Act/Anti-Money Laundering Examination Manual (“BSA Manual”).
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`The BSA Manual explains that an effective SAR program is essential:
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`Suspicious activity reporting forms the cornerstone of the BSA reporting system. It
`is critical to the United States’ ability to utilize financial information to combat
`terrorism, terrorist financing, money laundering and other financial crimes.
`Examiners and banks should recognize that the quality of SAR content is critical to
`the adequacy and effectiveness of the suspicious activity reporting system.1
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`17.
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`Pursuant to the BSA Manual, “[p]roper monitoring and reporting processes are
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`essential to ensuring that the bank has an adequate and effective BSA compliance program.
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`Appropriate policies, procedures, and processes should be in place to monitor and identify unusual
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`activity.” 2 When a bank detects suspicious activity, it is required to report that information within
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`30 days to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network
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`(“FinCEN”). The reporting requirement ensures that the government is able to monitor and act
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`when alerted to potential illegal conduct.
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`18.
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`Appendix F of the BSA Manual includes examples of suspicious transactions that
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`may indicate money laundering, terrorist financing, or fraud, including:
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`1 FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual, Suspicious Activity
`Reporting at 1 (2014)
`https://bsaaml.ffiec.gov/docs/manual/06_AssessingComplianceWithBSARegulatoryRequirement
`s/04.pdf.
`2 Id. at 2.
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 6 of 30
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`a.
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`b.
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`c.
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`d.
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`e.
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`Funds transfer activity is unexplained, repetitive, or shows unusual patterns;
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`The currency transaction patterns of a business show a sudden change
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`inconsistent with normal activities;
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`Unusual transfers of funds occur among related accounts or among accounts
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`that involve the same or related principals;
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`Currency is deposited or withdrawn in amounts just below identification or
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`reporting thresholds;
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`Regarding nonprofit or charitable organizations, financial transactions
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`occur for which there appears to be no logical economic purpose or in which
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`there appears to be no link between the stated activity of the organization
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`and the other parties in the transaction;
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`f.
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`Funds are sent or received via international transfers from or to higher-risk
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`locations.
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`19.
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`In addition, the CICO Act, 14 V.I.C. § 600, incorporates violations of Virgin Islands
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`Law and federal felonies, which includes the BSA and the USA PATRIOT Act.
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`II.
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`Jeffrey Epstein’s Criminal Conduct
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`20.
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`21.
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`Jeffrey Epstein was a resident of the Virgin Islands.
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`In 2008, Epstein pled guilty to one count of solicitation of prostitution with a minor
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`in Palm Beach, Florida. As a result of that conviction, Epstein was forced to register as a sex
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`offender in the Virgin Islands.
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`22.
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`Epstein was a Tier 1 offender under Virgin Islands law based upon his Florida
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`conviction of procuring a minor for prostitution.
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`23.
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`On January 15, 2020, the Government filed a lawsuit against Jeffrey Epstein’s
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`6
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 7 of 30
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`estate and related individuals and entities for violation of the CICO Act, 14 V.I.C. §§ 600 to 614,
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`and civil conspiracy, which the Government recently settled. As laid out in the Government’s
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`Second Amended Complaint, ST-20-CV-14, (“SAC”) (attached as Exhibit 1), Epstein created a
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`network of companies and individuals who participated in, directly or indirectly, and conspired with
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`him in a pattern of criminal activity related to the sex trafficking, forced labor, sexual assault, child
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`abuse, and sexual servitude of these young women and children. SAC ¶¶ 43-75. Epstein and his
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`associates trafficked underage girls to the Virgin Islands, held them captive, and sexually abused
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`them, causing them grave physical, mental, and emotional injury. Id.
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`24.
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`To accomplish this criminal activity, Epstein formed an association in fact with
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`both companies and non-profit organizations that he owned and operated, as well as individuals,
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`who were willing to participate in, directly or indirectly, facilitate, and conceal Epstein's criminal
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`activity in exchange for Epstein's bestowal of financial and other benefits, including sexual
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`services and forced labor from victims. Id. ¶¶ at 157-195.
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`25.
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`In October 2012, the Southern Trust Company—one of the companies Epstein
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`owned—applied for economic benefits from the Virgin Islands Economic Development
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`Commission (“EDC”) so the company could provide “cutting edge consulting services” in the area
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`of “biomedical and financial informatics.” Id. ¶¶ 157-158. Southern Trust Company received a 10-
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`year package of economic incentives running from February 1, 2013 until January 31, 2023 that
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`included a 90% exemption from income taxes and 100% exemptions from gross receipts, excise,
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`and withholding taxes in the Virgin Islands. Id. ¶ 159.
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`26.
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`Southern Trust, in fact, appeared to perform no informatics or data-mining services
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`during this period. Instead, Southern Trust funded the Epstein Enterprise (defined below), acting as
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`a conduit for payment to foreign women, credit cards, airplanes and other instrumentalities. Id.
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`7
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 8 of 30
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`¶¶ 167-173.
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`27.
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`This illicit association of Epstein, businesses, and his associates constitutes what is
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`referred to herein as the “Epstein Enterprise.” Specifically included in the Epstein Enterprise were
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`the following companies and non-profit organizations, all of which had accounts with JP Morgan:
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`2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education,
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`Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE,
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`LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company.
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`28.
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`Epstein used his wealth and power to create the Epstein Enterprise, which engaged
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`in a pattern of criminal activity by repeatedly procuring and subjecting underage girls and young
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`women to unlawful sexual conduct, sex trafficking, and forced labor.
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`29. Many of these women, particularly after Epstein’s conviction in 2008, were
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`trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint,
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`these women were recruited and, in several instances, required to marry other Epstein victims in
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`order to maintain their immigration status and their availability to Epstein. Id. ¶¶ 62- 63, 78, 86.
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`30.
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`As also alleged in the Second Amended Complaint, recruiters and victims were paid
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`in cash or through entities set up by Epstein and/or his associates. Id. ¶ 100. Many of these companies
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`were shell companies, that existed merely to transfer money to other accounts, or to shelter Epstein’s
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`assets from judgment. Id. ¶ 116.
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`31.
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`Epstein’s lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co-
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`Executors of Epstein’s Estate, authorized or directed many of the transactions in JP Morgan accounts
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`held by Epstein or related entities. Id. ¶¶ 8-10, 76-117.
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`32.
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`Epstein and the Epstein Enterprise continued trafficking and sexually abusing
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`young women and female children until Epstein was arrested by federal law enforcement
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`8
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 9 of 30
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`authorities on July 6, 2019 on federal charges for the sex trafficking of minors.
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`33.
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`Epstein was found dead on August 10, 2019 while in custody in a federal detention
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`center in New York on charges for sex-trafficking crimes. Id. ¶ 7.
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`ALLEGATIONS
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`I.
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`Jeffrey Epstein Was an Extremely High-Risk Customer
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`34.
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`Jeffrey Epstein’s reputation as a sex trafficker and abuser of women and girls was
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`well-known and well-publicized for more than a decade before his death.
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`35.
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`Between 2005 and 2013, there were numerous press reports that Epstein sexually
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`abused women and girls.
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`36.
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`In March 2005, there were press reports that Epstein paid a 14-year old girl in Palm
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`Beach, Florida for a “massage” and then molested her. Following these allegations, multiple
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`underage girls, many of them high school students, told police that Epstein also hired them to give
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`sexual massages.
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`37.
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`Throughout 2006—when Epstein was arrested in Palm Beach, Florida for
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`solicitation of a minor—there was extensive press regarding the nature and extent of Epstein’s
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`sexual offenses, including the existence of dozens of victims.
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`38.
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`In 2008, Epstein pled guilty to sexual offenses in Palm Beach, Florida, including
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`solicitating a minor for prostitution. Epstein was sentenced to 18 months in jail and was required
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`to register as a sex offender.
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`39.
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`In 2009, the non-prosecution agreement between Epstein and the United States
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`became public. It revealed allegations that Epstein may have used interstate commerce to induce
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`minors to engage in prostitution, engaged in illicit sexual conduct with minors, and trafficked
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`minors.
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 10 of 30
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`40.
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`In 2010, press reports noted allegations that Epstein was involved with Eastern
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`European women in particular and that a modeling agency he helped fund brought “young girls . .
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`. often from Eastern Europe” to the United States on Epstein’s private jets.3
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`II.
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`JP Morgan Knew Epstein Was a Felon, Registered Sex Offender, and Alleged Child
`Trafficker
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`41.
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`JP Morgan did business with Jeffrey Epstein from as early as
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`. In that
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`time, JP Morgan serviced approximately
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` Epstein-related accounts collectively worth
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`.
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`42.
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`3 Conchita Sarnoff, Jeffrey Epstein Pedophile Billionaire and His Sex Den, The Daily Beast (July
`22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den.
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 11 of 30
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`46.
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`47.
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`a59t6+++
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 12 of 30
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`III.
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`Head of JP Morgan’s Private Bank Had Close Personal Relationship With Epstein
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`51.
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`Former senior executive, Jes Staley (“Staley”), developed a close relationship with
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`Epstein when Staley was the head of JP Morgan’s Private Bank, which is a segment of JP Morgan’s
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`business dedicated to extremely wealthy clients with at least $10 million in assets.
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`52.
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`56.
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`At the time of Epstein’s death in 2019, Staley was the Chief Executive Officer of
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`Barclays; however, Staley stepped down from that position in November 2021 after British
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`financial regulators concluded an investigation into Staley’s characterization of his relationship
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`with Epstein.
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`IV.
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`JP Morgan Ignored Obvious Red Flags Relating to Epstein’s Accounts
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 14 of 30
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`61.
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`Each of these red flags was serious; together, they suggest a pattern of potentially
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`illegal conduct that should have prompted action by JP Morgan.
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`V.
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`Epstein Brought Additional High Net Worth Clients to JP Morgan
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`62.
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`J
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`69.
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`In January 2013—
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`of the Comptroller of the Currency (“OCC”) entered into a consent order with JP Morgan regarding
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`deficiencies in the bank’s overall program for BSA/AML compliance. The OCC found—
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`consistent with the Government's findings here—that JP Morgan failed to develop adequate due
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`diligence on customers and failed to comply with federal banking regulations. In fact, the OCC
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`noted that JP Morgan “failed to identify significant volumes of suspicious activity”.4
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`70.
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`.
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`71.
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`The New York State Department of Financial Services (“NYSDFS”) investigated
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`Deutsche Bank for failures to monitor Epstein’s accounts. On July 6, 2020, the NYSDFS and
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`Deutsche Bank entered into a Consent Order with a $150 million penalty, which stated, in relevant
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`parts:
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`a.
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`“The Bank’s fundamental failure was that, although the Bank properly
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`4 NYSDFS Consent Order at 2-4 (Jan. 14, 2013), https://www.occ.treas.gov/news-
`issuances/news-releases/2013/nr-occ-2013-8a.pdf.
`16
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 17 of 30
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`classified Mr. Epstein as high-risk, the Bank failed to scrutinize the activity
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`in the accounts for the kinds of activity that were obviously implicated by
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`Mr. Epstein’s past. The Bank was well aware not only that Mr. Epstein had
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`pled guilty and served prison time for engaging in sex with a minor but also
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`that there were public allegations that his conduct was facilitated by several
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`named co-conspirators. Despite this knowledge, the Bank did little or
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`nothing to inquire into or block numerous payments to named co-
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`conspirators, and to or on behalf of numerous young women, or to inquire
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`how Mr. Epstein was using, on average, more than $200,000 per year in
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`cash.”
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`b.
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`“Whether or to what extent those payments or that cash was used by Mr.
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`Epstein to cover up old crimes, to facilitate new ones, or for some other
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`purpose are questions that must be left to the criminal authorities, but the
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`fact that they were suspicious should have been obvious to Bank personnel
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`at various levels. The Bank’s failure to recognize this risk constitutes a
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`major compliance failure.”
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`c.
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`“These errors are unacceptable in the context of a major international bank
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`and inexcusable in the context of the heightened scrutiny that should have
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`occurred in the monitoring of a high-risk customer.”
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`72.
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`The NYSDFS also found fault with Deutsche Bank’s failure to obtain answers
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`regarding Epstein’s use of his accounts to pay women with Eastern European surnames: “In a May
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`2018 email, a compliance officer submitted an inquiry . . . about payments to the accounts of
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`women with Eastern European surnames at a Russian bank, and asking for an explanation of the
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`17
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 18 of 30
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`purpose of the wire transactions and Epstein’s relationship with the counterparties.”5
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`73.
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`VI.
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`JP Morgan Fraudulently Concealed Its Continuing Violations
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`74.
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`75.
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`JP Morgan’s continuous illegal conduct has caused repeated and continuous injury.
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`JP Morgan ignored numerous red flags and failed to comply with federal banking regulations until
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`years later after JP Morgan was no longer benefiting from Epstein’s business.
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`76.
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`JP Morgan also engaged in a course of conduct aimed at fraudulently concealing
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`its illegal conduct, including by failing to timely comply with federal banking regulations in order
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`to profit from Epstein’s wealth and connections.
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`77.
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`A key purpose of federal banking regulations is to give law enforcement real-time
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`information so that it can act to detect violations of the law and protect public safety.
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`78.
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`The Government of the Virgin Islands did not know, and could not have known,
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`that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind
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`eye to unusual cash transactions and wires and failed to carry out or follow up on basic due
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`diligence and to timely comply with federal banking regulations, as required by the law.
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`5 Id. at 15.
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`18
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 19 of 30
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`79.
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`Over more than a decade, JP Morgan clearly knew it was not complying with
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`federal regulations in regard to Epstein-related accounts as evidenced by its too-little too-late
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`efforts after Epstein was arrested on federal sex trafficking charges and shortly after his death,
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`when JP Morgan belatedly complied with federal law.
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`80.
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`The continued illegal conduct by JP Morgan has caused repeated and continuous
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`injury. JP Morgan’s illegal conduct was not completed nor were all damages incurred until the
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`wrongdoing ceased in August 2019 when JP Morgan began belatedly complying with federal
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`banking regulations in regard to Epstein-related accounts.
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`CAUSES OF ACTION
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`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)
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`81.
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`The Government restates and realleges paragraphs 1 to 80 of this Complaint as if
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`fully set forth herein.
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`82.
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`The Government brings this Count as parens patriae on behalf of the residents and
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`visitors of the United States Virgin Islands and pursuant to the Attorney General’s express
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`statutory authority.
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`83.
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`JP Morgan knowingly and intentionally participated in Epstein’s sex-trafficking
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`venture that was in and affecting interstate and foreign commerce, together and with others, in
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`violation of 18 U.S.C. § 1591(a)(2) by
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`
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`, and concealing Epstein’s criminal conduct by failing to comply
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`with federal banking law.
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`84.
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`JP Morgan knowingly and intentionally benefitted financially from and received
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`value for its participation in the sex-trafficking venture in which Epstein and his co-conspirators,
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`19
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 20 of 30
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`with JP Morgan’s knowledge or reckless disregard of the fact, would use means of force, threats
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`of force, fraud, coercion, and a combination of such means to sexually abuse young women and
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`underage girls, including by causing them to engage in commercial sex acts, in the Virgin Islands
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`and elsewhere.
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`85.
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`Among the financial benefits that JP Morgan received for participating in and
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`facilitating Epstein’s sex-trafficking venture was the deposit of funds that Epstein—a Virgin
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`Islands resident—and Epstein-controlled entities located in the Virgin Islands made to JP Morgan.
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`JP Morgan profited from the use of these deposits. Epstein and Epstein-controlled entities located
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`in the Virgin Islands deposited these funds in exchange for JP Morgan’s facilitation of and
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`participation in Epstein’s sex-trafficking venture.
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`86.
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`Also, among the financial benefits that JP Morgan received for participating in and
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`facilitating Epstein’s sex-trafficking venture were
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`
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`.
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`87.
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`JP Morgan financially profited from the deposits made by Epstein and Epstein-
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`controlled entities located in the Virgin Islands and from
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`
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` in exchange for its known facilitation of and implicit
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`participation in Epstein’s sex trafficking venture.
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`88.
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`JP Morgan knew and recklessly disregarded and concealed the fact that it was
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`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
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`20
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 21 of 30
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`underage girls for purposes of causing them to engage in commercial sex acts in violation of 18
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`U.S.C. § 1591(a)(1).
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`89.
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`JP Morgan and its employees had actual knowledge that they were facilitating
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`Epstein’s sexual abuse and sex-trafficking conspiracy to recruit, entice, harbor, transport, provide,
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`obtain, and maintain young women and underage girls to engage in commercial sex acts through
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`the means of force, threats of force, fraud, abuse of process, and coercion.
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`90.
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`Despite this knowledge, JP Morgan intentionally paid for, concealed, facilitated,
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`and participated in Epstein’s and his co-conspirators’ violations of 18 U.S.C. § 1591(a), which JP
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`Morgan knew and was in reckless disregard of the fact that Epstein and his co-conspirators would
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`use its bank accounts and financial transactions to coerce, defraud, and force young women and
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`underage girls to engage in commercial sex acts.
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`91.
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`JP Morgan, through its employees and agents and their role in facilitating the
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`financial aspect of Epstein’s enterprise, actively facilitated or participated in the sex-trafficking
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`conspiracy in which Epstein and his co-conspirators led young women and underage girls in the
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`Virgin Islands and elsewhere to believe that they would be rewarded if they cooperated with
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`Epstein and his co-conspirators and acquiesced to their demands.
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`92.
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`JP Morgan committed this affirmative conduct knowing or in reckless disregard of
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`the fact that Epstein would use cash transactions and financial support provided by JP Morgan as
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`a means to defraud, force, and coerce commercial sex acts from young women and underage girls.
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`93.
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`In addition to having actual knowledge that it was participating in and facilitating
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`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. §
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`1591(a)(1).
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`21
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 22 of 30
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`94.
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`In exchange for facilitating and covering up Epstein’s commercial sex trafficking,
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`JP Morgan’s employees received financial benefits and career advancement from JP Morgan.
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`95.
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`Facilitating and covering up Epstein’s sex trafficking venture was a means for JP
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`Morgan employees to obtain economic success and promotion within JP Morgan.
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`96.
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`JP Morgan’s knowing and intentional conduct has caused serious harm to the
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`Virgin Islands and its residents, including without limitation financial harm, by facilitating the
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`commission of sexual abuse against young women and underage girls, including their engagement
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`in commercial sex acts, in the Virgin Islands.
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`97.
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`JP Morgan’s tortious conduct in violating the TVPA was outrageous and intentional
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`because it was in deliberate furtherance of a widespread and dangerous criminal sex-trafficking
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`venture operated in and from the Virgin Islands. JP Morgan’s tortious conduct also evidenced a
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`high degree of moral turpitude and demonstrated such wanton disregard for the safety of young
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`women and underage girls in the Virgin Islands and elsewhere as to imply a deliberate indifference
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`to its legal obligations.
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`98.
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`By virtue of these knowing and intentional violations of 18 U.S.C. § 1591(a)(2), JP
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`Morgan is liable to the Government for all appropriate relief under 18 U.S.C. § 1595(d), including
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`damages suffered by the Government and/or Epstein’s victims, punitive damages, restitution,
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`appropriate injunctive relief, fines, reasonable attorneys’ fees, and all such other relief as the Court
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`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)
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`22
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`Case 1:22-cv-10904-UA Document 1 Filed 12/27/22 Page 23 of 30
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`99.
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`The Government restates and realleges paragraphs 1 to 98 of this Complaint as if
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`funny set forth herein.
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`100.
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`The Virgin Islands Legislature enacted the CICO Act with the purpose to “curtail
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`criminal activity and lessen its economic and political power in the Territory of the Virgin Islands
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`by establishing new penal prohibitions and providing to law enforcement and the victims of
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`criminal activity new civil sanctions and remedies.” 14 V.I.C. § 601.
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`101. At all times material herein, JP Morgan was a “person” identified in 14 V.I.C. §
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`604(l).
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`102. At all times material herein, Epstein and his co-conspirators were engaged in an
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`illicit sex-trafficking “enterprise” as defined in 14 V.I.C. § 604(h).
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`103. At all times material herein, JP Morgan supported and/or was associated with the
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`Epstein sex-trafficking enterprise by providing banking and payment-processing services to