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failed to file with the federal government the required SARs that financial institutions must file with the Financial Crimes Enforcement Network ("FinCEN") whenever there is a suspected case of money laundering or fraud. Timely filing of these reports is required by the Bank Secrecy Act and related l
ated the laws against sex trafficking. This action is also timely because the conspiracy continued until recently. This action is also timely under New York's Adult Survivor's Act, N.Y. CPLR § 214-j. II. PARTIES 7. Jane Doe 1 is a U.S. citizen and was at all relevant times a resident of and domiciled in
as 2012, a JP Morgan subsidiary company assisted with transporting certain Epstein sex-trafficking victims by private jet from Florida to Epstein in New York. 177. Ultimately, JP Morgan financially benefited by earning millions of dollars for its participation in the Epstein sex-trafficking venture. 178
forcement Network (FinCEN) May 2015 Record of Authorization to Electronically File FBARs (See instructions below for completion) Do not send to FinCEN. Retain this form for your records. ANASTAS20170001 The form 114a may be digitally signed Part I I Persons who have an obligation to file a Report
ions (but not those of NYS or its local governments) 21 Public employee 414(h) retirement contributions from your wage s tatements (see page 16) 22 New York's 529 college savings program distributions (see 23 Other (Form 1T-225, line 9) 24 Add lines 19 through 23 New York subtractions (see page 17) 2
forcement Network (FinCEN) May 2015 Record of Authorization to Electronically File FBARs (See instructions below for completion) Do not send to FinCEN. Retain this form for your records. TM form 114a may be digitally signed Part I I Persons who have an obligation to file a Report of Foreign Bank a
ons (but not those of NYS or its local governments) 21 Public employee 414(h) retirement contributions from your 4lage statements (sea Page 16) 22 New York's 529 college savings program distributions 23 Other (Form IT-225, line 9) 24 Add lines 19 through 23 New York subtractions (see page 17) 25 Taxabl
cement Network (FinCEN) I May 2015 Record of Authorization to Electronically File FBARs (See instructions below for completion) Do not send to FinCEN. Retain this form for your records. ANASTAS20170001 The fomi 114a may be digitally signed Part I I Persons who have an obligation to file a Report
obligations (but not those of NYS or its local governments) 21 Public employee 414(h) retirement contributions from yo s tatements (seepage 16) 22 New York's 529 college savings program distributions 23 Other (Form 1T-225, line 9) 24 Add lines 19 through 23 New York subtractions (see page 17) 25 Taxabl
ists, and transnational organized criminals." 24 EFTA00151518 79. On July 15, 2014, the U.S. Treasury's Financial Crimes Enforcement Network ("FinCEN") named FBME a foreign financial institution of primary money laundering concern pursuant to Section 311 of the USA PATRIOT Act (the "311 Designatio
r that month, on January 22, 2015, in preparation for the ARRC meeting, EXECUTIVE-1 and RELATIONSHIP MANAGER-1 met in person with Mr. Epstein at his New York home. During the meeting, EXECUTIVE-1 asked Mr. Epstein about the veracity of the recent allegations and appeared to be satisfied by Mr. Epstein's r
to Epstein's foreign financial transactions? EFTA00152225 -Have local New York and Florida banks filed Currency Transaction Reports (CTRs) with FinCEN regarding cash deposits and/or withdrawals by Epstein that might explain the "tons of cash" found in his safe? CAUSES OF ACTION FIRST CAUSE OF ACT
1 and 302, in that the Defendants named herein reside in and/or conduct business in New York, and, at times relevant herein, conducted activities in New York that gives rise to the claims asserted in the State of New York. The United States Constitution, in Article III, § 2, gives the Congress the power
to Epstein's foreign financial transactions? EFTA01721828 -Have local New York and Florida banks filed Currency Transaction Reports (CTRs) with FinCEN regarding cash deposits and/or withdrawals by Epstein that might explain the "tons of cash" found in his safe? CAUSES OF ACTION FIRST CAUSE OF ACT
1 and 302, in that the Defendants named herein reside in and/or conduct business in New York, and, at times relevant herein, conducted activities in New York that gives rise to the claims asserted in the State of New York. The United States Constitution in Article III, § 2 gives the Congress the power to
tness of the bank's compliance culture. BARCLAYS AND THE FACILITATION OF TRANSACTIONS FOR THE ROTENBERGS 27. Is it true that Barclays reported to FinCEN at the end of November 2016 that from March 2012 to March 2016 it had done transactions worth $728,288.65 to offshore companies Stormont Systems Lt
Bank reported $4.2 million going through Barclays accounts in Monaco and Botswana, and through correspondent banking accounts with Barclays Bank in New York, according to a look-back SARs filed with FinCEN. These funds have been identified as part of the bribery of Olympics officials. 46. Why was Barcla
s enforcement of the TVPA, JP Morgan failed to timely file with the federal government the required SARs that financial institutions must file with FinCEN whenever there is a suspected case of money laundering or fraud. Timely filing of these reports is required by the Bank Secrecy Act and related law
dyke and Kahn signed company checks for combined value of almost $300,000 made out personally to young women or to, again, the immigration lawyer in New York who was involved in one or more forced marriages arranged among Epstein's victims to secure a victim's immigration status. 96. Upon information an
activity, it is required to report that information within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The reporting requirement ensures that the government is able to monitor and act FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual,
dyke and Kahn signed company checks for combined value of almost $300,000 made out personally to young women or to, again, the immigration lawyer in New York who was involved in one or more forced marriages arranged among Epstein's victims to secure a victim's immigration status. 96. Upon information an
Entities connected to both FinCEN and New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSONDarren Indyke
PERSON
New York City
LOCATION
U.S. Virgin Islands
LOCATIONFBI
ORGANIZATION
John F. Kennedy
PERSON
Samantha Power
PERSON