Epstein Secrets

ereinafter referred to collected as "Deutsche Bank"), participating in and financially benefitting from their direct and intentional involvement in Jeffrey Epstein's sex-trafficking venture by providing the financial lifeblood and infrastructure for the venture's continued operation. Deutsche Bank knowingly bene

ank knowingly benefited and received things of value for assisting, supporting, facilitating, and otherwise providing the most critical tool for the Jeffrey Epstein sex-trafficking organization to successfully rape, sexually assault, and coercively sex traffic Plaintiff and the numerous other members of

ngly benefited and received things of value for assisting, supporting, facilitating, and otherwise providing the most critical tool for the Jeffrey Epstein sex-trafficking organization to successfully rape, sexually assault, and coercively sex traffic Plaintiff and the numerous other members of the clas

pliance, Americas, reiterated the ARRC's decision in an email to other executives, stating that ARRC had agreed to "continue business as usual with Jeff Epstein" based upon Packard's "due diligence [bar] visit with him." Deutsche Bank knew, and was acting in reckless disregard of the fact, that Epstein's 65

f Florida found that some of the victims "went to Mr. Epstein's house only once, some went there as much as 10

al behavior in participating in Epstein's sex-trafficking venture. 2. Banking Regulations Exist to Help Prevent Funding of Criminal Ventures. 178. The Federal Bank Secrecy Act ("BSA") requires financial institutions to have adequate anti-money laundering ("AML") policies and systems in place. New York state law requires f

A00151495 WHEREAS, the Department has been investigating various aspects of Deutsche Bank's operations, specifically, the Bank's relationship with Jeffrey Epstein and related entities and correspondent and dollar-clearing relationships with the Federal Bank of the Middle East Ltd. ("FBME") and Danske Bank A/S

ions fully with respect to three different customer relationships: one direct customer relationship with Jeffrey Epstein and entities related to Mr. Epstein; and two dollar- 3 EFTA00151497 clearing/correspondent banking relationships with foreign banks, FBME and Danske. Each will be addressed in turn.

ce officer followed up, asking "[w]tty is this client using this account to . . . pay school tuition?," RELATIONSHIP MANAGER-2 replied "[g]enerally, Jeffrey has separate 15 EFTA00151509 accounts to manage each of his properties. This is one of them. However, when making one-off transfers to people, h

ship with Jeffrey Epstein and entities related to Mr. Epstein; and two dollar- 3 EFTA00151497 clearing/corre

institutions act as a critical line of defense against illegal financial transactions in an ever changing and interconnected financial network. 2. The Federal Bank Secrecy Act ("BSA") requires financial institutions to have adequate anti-money laundering ("AML") policies and systems in place. New York State law requires f

.Y. CPLR §214-j. The suit arises from Defendant JP Morgan Chase Bank, N.A.'s (hereinafter "JP Morgan") participation and intentional involvement in Jeffrey Epstein's widespread and well-publicized sex-trafficking operation, as well as the direct financial benefits it received therefrom. JP Morgan knew that it wa

ficking operation, as well as the direct financial benefits it received therefrom. JP Morgan knew that it was providing the financial lifeblood for Epstein's 1 EFTA00162121 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 2 of 130 international sex-trafficking organization from 1998 through Au

n") participation and intentional involvement in Jeffrey Epstein's widespread and well-publicized sex-traf

horities found that some of the victims "went to Mr. Epstein's house only once, some went there as much as 10

n in 2013. C. JP Morgan's Role in the Sex-Trafficking Venture 1. Banking laws and regulations exist to prevent funding of criminal ventures. 116. The Federal Bank Secrecy Act ("BSA") requires financial institutions 30 EFTA00162150 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 31 of 130 to have adequate anti-m