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n known as Federal Financial Institutions Examination Council ("FFIEC"). 16. To provide further guidance to banks on what BSA compliance requires, FFIEC published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). The BSA Manual explains that an effective SAR program is esse
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
n known as Federal Financial Institutions Examination Council ("FFIEC"). 16. To provide further guidance to banks on what BSA compliance requires, FFIEC published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). The BSA Manual explains that an effective SAR program is esse
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
n known as Federal Financial Institutions Examination Council ("FFIEC"). 16. To provide further guidance to banks on what BSA compliance requires, FFIEC published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). The BSA Manual explains that an effective SAR program is esse
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 FFIEC and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSONJEGE, Inc.
ORGANIZATION
New York
LOCATIONJane Doe
PERSON
Les Wexner
PERSON
Glenn Dubin
PERSONGratitude America
ORGANIZATIONHyperion Air
ORGANIZATION
Eastern Europe
LOCATIONLarry Visoski
PERSON
Financial Trust Company
ORGANIZATIONThe Government of the Virgin Islands
ORGANIZATIONHBRK Associates
ORGANIZATIONthe Epstein Estate
ORGANIZATIONSecond Amended Complaint
ORGANIZATION
Financial Crimes Enforcement Network
ORGANIZATIONCoatue Enterprises
ORGANIZATION