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to JP Morgan. 84. In addition to the many civil lawsuits seeking damages for sexual abuse, Epstein's victims also filed a public lawsuit against the Unites States under 18 U.S.C. § 3771, the Crime Victim's Rights Act ("CVRA"), further exposing Epstein's sexual crimes as well as his secret Non-Prosecution Agre
trafficking for violations of 18 U.S.C. § 1591, in part due to Epstein's criminal activities in his New York Mansion located at 9 East 71st Street. See United States v. Jeffrey Epstein, Case No. 1:19-cr-00490 (S.D.N.Y.). 90. On July 8, 2019, Epstein was arrested pursuant to the New York Indictment. 91. On Au
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
trafficking for violations of 18 U.S.C. § 1591, in part due to Epstein's criminal activities in his New York Mansion located at 9 East 71st Street. See United States v. Jeffrey Epstein, Case No. 1:19-cr-00490 (S.D.N.Y.). 123. On July 8, 2019, Epstein was arrested pursuant to the Southern District of New York In
f AML Compliance for Deutsche Bank Americas and the then-General Counsel for Deutsche Bank Americas, who at that time served as chair of the Bank's Americas Reputational Risk Committee ("ARRC")]. Neither suggest [that the Epstein 52 EFTA00162009 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page
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
E STREET NEW YORK, NEW YORK 10004 x In the Matter of DEUTSCHE BANK AG, DEUTSCHE BANK AG NEW YORK BRANCH, and DEUTSCHE BANK TRUST COMPANY OF THE AMERICAS : --------------------------------------------- ----------- -x CONSENT ORDER UNDER NEW YORK BANKING LAW 44 39 and 44 The New York State Departm
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
Entities connected to both United States and The Federal Bank Secrecy Act

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
New York
LOCATION
Marc Rich
PERSON
Lesley Groff
PERSON
Southern District of New York
ORGANIZATION
Deutsche Bank
ORGANIZATION
New York State
LOCATION
Sarah Kellen
PERSONthe State of New York
LOCATION
JPMorgan Chase
ORGANIZATIONNadia Marcinkova
PERSON
Jean-Luc Brunel
PERSON
Frankfurt
LOCATION
Jes Staley
PERSONSouthern Trust Company
ORGANIZATION
Eastern Europe
LOCATION
Financial Services
ORGANIZATION