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stein. The co-conspirators who benefitted 107 EFTA00162227 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 108 of 130 financially include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Acting through its officers and employees (including Staley), JP Morgan itself
co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. The federal criminal investigation of Maxwell included investigation of possible 122 EFTA00162242 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 123 of 130 violations of the TVPA. 4
led 01/13/23 Page 108 of 130 financially include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross,
ndicted Epstein (and unnamed "associates") for violating the TVPA. Later, on about June 29, 2020, the same Office indicted Epstein's co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. The federal criminal investigation of Maxwell included investigation of p
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
or payment for services as a procurer." 49. In August 2011, when conducting a Know-Your-Customer review, JP Morgan flagged an account relating to Ghislaine Maxwell—Epstein's former companion who recently was sentenced to 20 years in prison for conspiring with Epstein to sexually abuse minors. Maxwell wanted to
Ghislaine Maxwell—Epstein's former companion who recently was sentenced to 20 years in prison for conspiring with Epstein to sexually abuse minors. Maxwell wanted to set up an account for her "personal recruitment consulting business." In an internal email, JP Morgan's AML Director asked: "What does sh
review, JP Morgan flagged an account relating to Ghislaine Maxwell—Epstein's former companion who recently w
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
he Mirror reported." Lang "offered to talk with FBI investigators after he received a plea from Virginia Guiffre, who has accused British socialite Ghislaine Maxwell of arranging for her to have sex with the disgraced royal when she was only 17." The Sun (UK) (9/18, 712K) also reports. OTHER FBI NEWS Rubio: FBI
fre, who has accused British socialite Ghislaine Maxwell of arranging for her to have sex with the disgrac
ginia Guiffre, who has accused British socialite Ghislaine Maxwell of arranging for her to have sex with the
." The documents include "leaked suspicious activity reports (SARs) filed by banks and other financial firms with the U.S. Department of Treasury's Financial Crimes Enforcement Network (FinCen)." These SARs "were EFTA00148946 obtained by BuzzFeed News and shared with the International Consortium of Investigative Journalists (ICI
The Mirror reported." Lang "offered to talk with FBI investigators after he received a plea from who has accused EFTA01658678 British socialite Ghislaine Maxwell of arranging for her to have sex with the disgraced royal when she was only 17." The Sun (UK). (9/18, 712K) also reports. OTHER FBI NEWS Rubio: FB
cused EFTA01658678 British socialite Ghislaine Maxwell of arranging for her to have sex with the disgrac
who has accused EFTA01658678 British socialite Ghislaine Maxwell of arranging for her to have sex with the
." The documents include "leaked suspicious activity reports (SARs) filed by banks and other financial firms with the U.S. Department of Treasury's Financial Crimes Enforcement Network (FinCen)." These SARs "were obtained by BuzzFeed News and shared with the International Consortium of Investigative Journalists (ICIJ) and other me
Entities connected to both Ghislaine Maxwell and Financial Crimes Enforcement Network

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
JPMorgan Chase
ORGANIZATIONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSONLeon Black
PERSON
Eric Trump
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSON
Les Wexner
PERSONFBI
ORGANIZATIONJane Doe
PERSONEmmy Taylor
PERSON