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ing 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 t
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
ing 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 t
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
ing 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 t
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 The Government of the Virgin Islands and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
U.S. Virgin Islands
LOCATION
Ghislaine Maxwell
PERSONV.I.C.
ORGANIZATIONthe Territory of the Virgin Islands
LOCATIONLarry Visoski
PERSONHyperion Air
ORGANIZATIONSouthern Trust Company
ORGANIZATION
Financial Trust Company
ORGANIZATIONGREAT ST
ORGANIZATION
Great St. James
ORGANIZATION
St. John
LOCATIONProstitution and Related Offenses
ORGANIZATION
Water Island
LOCATION
United States
LOCATION
Little St.
LOCATIONExpedited Motion for Establishment of a
ORGANIZATION
St. Croix
LOCATION