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tivity."2 When a bank detects suspicious 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 when alerted to potential illegal conduct. 18. Appen
addition, Epstein and/or his representatives appeared to be misusing JP Morgan accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
tivity."2 When a bank detects suspicious 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 AcUAnti-Money Laundering Examinatio
CGLacs e. 22-1kod.-CIfia91143BRDOnntuantataa PDS EIC1O12/23 Page 11B aff ain accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
tivity."' When a bank detects suspicious 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 Examinati
EFTA00161851 Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 17 of 34 accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
Entities connected to both Financial Crimes Enforcement Network and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSON
FinCEN
ORGANIZATIONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Richard Kahn
PERSON
New York
LOCATIONJEGE, Inc.
ORGANIZATIONSouthern District
LOCATIONJane Doe
PERSON
JPMorgan Chase
ORGANIZATION
Washington D.C.
LOCATION
Glenn Dubin
PERSON
Eastern Europe
LOCATION
Deutsche Bank
ORGANIZATION
U.S. Virgin Islands
LOCATION
Les Wexner
PERSONSouthern Trust Company
ORGANIZATION
United States
LOCATION
Jes Staley
PERSONFederal and State Legal Requirements
ORGANIZATION